ML19339A524

Responds to Public Meeting 800819 Request for Util Analysis & Response to Bechtel Recommendations.Specific Responses Encl

ML19339A524
Person / Time
Site:	South Texas
Issue date:	09/24/1980
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19339A516	List: ML19339A515 ML19339A518 ML19339A522 ML19339A524
References
ST-HL-AE-548, NUDOCS 8011040188
Download: ML19339A524 (7)

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- The Light Company n.,iisi.,,, ugi,iii,8 & n,= m 8.,x iwi n.,usi... .nxas muii vi3im.nii September 24, 1980 ST-HL-AE-548 SFN: C-0510 Mr. Karl Seyfrit Direc1or, Region IV Nuclear Regulatory Comission 611 Ryan Plaza Drive, Suite 1000 ArIington, Texas 76012

Dear Mr. Seyf rit:

South Texas Project Units la2 Docket Nos. STN 50-498, STN 50-499 Response to Bechtel Recommendations As requested in the Public Meeting of August 19, 1980 and identified as Hl2 in our Commitment List submitted to you on September 18, 1930, this letter with its attachment reoresents Houston Lighting & Power Company's analysis and response to the Bechtel recommendations.

Should you have any questions please advise.

Very truly yours,

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O .M '[g#

Exec ive Vide President GWO/ngb Attachment e

8011040/EP

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.. Houston Ughting 8: Power Cannpany September 24,1980 ST-HL-AE-548 SFN: C-0510 Paoe 2 cc: D. G. Barker Howard Pyle .

H. R. Dean

.R. L. Beeth l J. D. Parsons i R. L. Waldrop A. J. Granger R. A. Frazar M. D. Scwharz (Baker & Botts)

R. Gordon Gooch (Baker &Botts)

J. R. Newman (Lowenstein, Newman, Reis, Axeir.d & Toll)

Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C. 20555 M. L. Borchelt Executive Vice President Central Power & Light Company P. O. Box 2121 Corpus Christi, Texas 78403 R. L. Range Central Power & Light Company P. O. Box 2121 Cnrpus Christi, Texas 78403 R. L. Hancock Director of E~iectrical Utilities City of Austin P. O. Box 1088 Austin, Texas 78767

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T. H. Muehlenbeck City of Austin P. O. Box 1088 Austin, Texas 78767 J. B. Poston

, Assistan General Manager of Operations City Public Scivice Board P. O. Box 1771 San Antonio, Texas 78296 A. vonRosenbera

"~ City Public Service Board .

P. O. Box 1771 San Antonio, Texas 78295 r

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September 24, 1980 Nusi m tighting& Pin er C. imp. ins ST-HL-AE-548 SFN: C-0510 Page 3 Charles Bechoefer, Esquire Cha'irman, Atomic Safety & Licensing Board 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 & Licensing Commission U. S. Nuclear Regulatory Connission Washington, D. C. 20555 Steven A. Sinkin, Esquire 116 Villita Street San Antonio, Texas 78205 Citizens for Equitable Utilities c/o Ms. Peggy Buchorn Route 1. Box 432 Brazoria, Texas 77422 Richard W. Lowerre Esquire Assistant Attorney General for the State of Texas P. O. Box 12548 Capitol Station Austin, Texas 78711

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Henry J. McGurren, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 i

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l SOUTH TEXAS PROJECT RESPONSE TO BECHTEL RECOMMENDATIONS

1. Procedures A. Recomendation: It is recommenced that a task force from

- both HL&P and B&R be organized for the purpose of reviewing function.nl procedures.

Response: Joint effort by HL&P and B&R is underway to review and revise procedures. A complete rewrite of B&R QA and Construction procedures is ongoing to simplify the instructions, clarify the inspection requirements, and ensure compatibility with our comitments. The Construction procedures are reviewed by Design Engineering to ensure that design requirements will be satisfied.

The HL&P and B&R QA procedures are under revision to incorporate all the 79-19 program changes and organizational restructuring.

B. Recomendation: HL&P QA should coardinate and track the task force effort.

Response: HL&P QA is working c' osely with B&R arid is 1 tracking the results and progrr ss of the procedure rewrites.

l C. Recommendation: A matrix shoild then be structured to identify how requirements and commitments are met by l functional procedures. ,

Response: The use of a matrix is under review. It would come into use after procedures have been revised.

D. Recomendation: Once the functional procedures are in place, a six-month hiatus should be imposed on further program development or revisions.

Response: We are pursuing stabilization of procedures through a course of making minimum changes to said procedures. Control of changes to procedures will be predicated on "the need to change".

II. Documentation and Analysis of Defects

_. Recomendation: It is recomended that HL&P and BAR management comit to prudent action for documenting trends of nonconformance and program deficiencies identified by audit results.

Response: A trend analysis program for nonconformance identified 1

by audits and by quality control inspections has been established and is being implemented as described in our response to Show i

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Cause Item 6. (See pages 6-8 through 6-12 of the Show Cause response.)

III. Training and Qualification A Recommendation: A comprehensive program of quality i orientation, indoctrination to requirements, and functional training to procedures is recommended for personnel performing quality-related activities and for personnel performing quality surveillance or verification functions.

Response: A program of quality orientation, indoctrination to requirements, and functional training to procedures is being established for personnel performing quality-related activities and for personnel performing quality surveillance or verification functions for both Brown & Root and Houston Li,ghting & Power Company.

B. Recommendation: It is recommended that quality orientation and indoctrination programs involve HL&P and B&R personne1~ at dll levels, including management.

Response: The quality orientation and indoctrination program does involve Brown & Root and HL&P personnel at all levels, including management. It is noteworthy that the Brown & Root quality improvement program under the tutelage of Mr. Phil Crosby has been established and is being implemented.

C. Recommendation: Provisions should be made for follow-up or refresher training.

Response: Refresher training is seing addressed as part of the training programs for both Brown & Root and Houston Lighting & Power Company.

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D. Recommendation: It is further recommended that consideration be given to programs developed elsewhere in the industry.

Response: Training programs which have been developed outside the South Texas Project by others in the industry is being considered in the program for training of Helston Lighting & Power and Brown & Root personnel. .

IV. System Controls A. Recommendation: It is recommended that the STP QA program

- and its implementating procedures clearly identify responsibilities and reflect a closed-loop feedback concept that quality-related activities are initiated, performed, reviewed, and documented in the proper sequence.

Response: The closed-loop feedback concept is being incorporated into the STP QA program and procedure development effort. Careful planning for each construction 2

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- activity by Construction and Quality Engineering will be an integral part to ensure that the proper sequence of construction, inspection, and reporting results is performed to clearly established criteria.

B. Recommendation: It is further recommended that system flow diagrams be used to depict the sequence of activities as an aid to conveying system concepts to personnel.

Response: We have begun the use of system flow diagrams for some system development areas.

V. Audit System A. Recommendation: It is recommended that the B&R audit system incorporate distribution of audit reports to management at least two levels above the manager of the area audited.

Response: Effective September 8,1980, the following upper management personnel are on distribution for all inte.nal and site audit reports:

S. H. Grote, Senior Vice President K. H. Broom, Senior Vice President W. M. Rice, Group Vice President B. Recommmendation: It is further recomecr.Jed that the close-out of HL&P audit findings include verification of corrective action, including a reexamination of the area to determine current control.

Response: The audit procedure has been revised to reflect more positive control for the verification of corrective action, and follow-up audits have been incorporated into the audit schedule when required.

• C. Recommendation: Greater attention should be given to the selection, training, and qualification of auditors and lead auditors for both HL&P and B8R.

HL&P response: Auditors are being selected based upon the technical requirements of the area being audited.

B&R response: Scr?ening of applicants and greater attention to selection of udit personnel has been implemented. Highly qualified subcon;ract audit personnel have been added to 8&R staff in order to supplement the organizational needs until

~ additions to staff have been completed and qualified. New audit program indoctrination ered training have been performed and are ongoing.

,D. Recommendation: Emphasis should be placed on maintaining i accurate qualification records.

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HL&P response: Audit procedures have been revised to clarify how entries are to be made on the auditor qualification records. Additionally, the auditor qualification form is being revised to provide a comprehensive method of indicating auditor qualification levels.

BAR response: All personnel files were completely reviewed and updated as required to assure that substantiation of the basis for qualification is documented.

i VI. Management Involvement A. Recommendation: It is recommended that both HL&P and BAR management take immediate steps to demonstrate their comitment to quality performance and their unequivocal support of the STP QA program.

i Response: Both Brown & Root and HL&P management have taken firm steps to demonstrate their commitment to quality performance and support of the QA program. Evidence of this is the establishment of the quality improvement programs within Brown & Root, the conduct of various meetings and seminars by Brown & Root management with various levels of management and supervision in the Brown & Root organization, including Mr. Rice's address to some 600 Brown & Root employees in which he stated unequivocally the support of the QA program. Additionally, Mr. Oprea's meetings with the proje" team and the performance of both managements in the publim meeting demonstrated the support for the quality assurance program. Also, the additional time being spent by top management of both companies on the site interfacing with all levels of QA/QC personnel and construction personnel is evidence of their support for the quality assurance program.

Brown & Root also has issued the text of Mr. Rice's address as a policy regarding the quality assurance program for the project.

• B. llecomendation: It is further recommended that the QA organizations be revamped to overcome noted weaknesses.

Response: The organizations of both Brown & Root and Houston Lighting & Power Company for quality assurance have been revamped to overcome n.oted weaknesses.

C. Recommendation: The respective QA functions of HL&P and BAR .

should be examined to ensure independent yet complementary QA practices.

Response: The quality assurance functions of Houston 1.ighting & Power and Brown & Root have been examined together by both MAC and Bechtel, and the new organization and definition of the role of programmatic direction on the part of Houston Lighting & Power and programatic implenientation by Brown & Root have ensured independent but complementary QA practices. Implementation of this philosophy is ongoing.

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l~ The Light l COmpMy noo, ion tighting& Power P.o.nox1700 Houston. Texas 77001 (713)228-9211 September 24, 1980 ST-HL-AE-541 SFN: C-0510

' Mr. Karl Seyfrit

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Director, Region IV r Nuclear Regulatory Comission 611 Ryan Plazr Drive, Suite 1000 Arlington, Texas 76012

Dear Mr. Seyfrit:

South Texas Project

.f Units 1&2 Docket Nos. STN 50-498, STN 50-499 Criteria For Quality Assurance ,

Staffing Levels As requested in the public meeting of August 19,1980, and identified as H-15 in our comitment list submitted to you on September 18,1980, this l letter des ribes the criteria for establishing the staffing levels for '

Houston LNhting & Power Company's site Quality Assurance organizatior. to support our quality assurance program at the South Texas Project. Personnel projections through the end of 1986, as shown on the attached functional organization chart and manloading curves, (attachment 1) were arrived at using the following approach.

For each functional section of the site organization, we identified the .

specific quality assurance activities (job duties and responsibilities) that individuals in that part of the organization are responsible for accomplishing.

We determined for each of those activities the number of man-hours required to

] accomplish the job and used those man-hours, considering the schedular flow of project activities from the present through the end of the job, to calculate the l number of personnel in each segment of the organization required to support the

.i activities of that segment. '

f The attached graph depicts man-loading curves by discipline and resulting H

3 total requirements necessary to support the quality assurance program through 1986. We intend to add personnel to the organization according to the curves shown on the graph. The people added will be experienced personnel in order to maximize the effectiveness of the additions. Should anticipated requirements not materialize or change in time, we will accordingly adjust our need either up or down, depending on circumstances.

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1 september 24, 1980 l h l @ 4 & N C 'nPa"J ST-HL-AE-541 SFN: C-0510 Page 2 Required experience levels will be established on an individual basis by the Project QA Supervisor and the Projrct QA Manager, with considerationEach given to the experience level that exist 3 within the group.

have a mixture of people with varying degrees of experience.

Our work papers establishing tne numbers represented by each of the

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curves on attachment 1 is available for review should you desire to do so.

f; If you have any questions, please contact me.

Very truly ours, j i

Exe tive V ce President GWO/pjb Attachment i

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I September 24, 1980 Houuon Lighting L Power Compan)

ST-HL-AE-541 SFN: C-0510 Page 3 cc: D. G. Barker Howard Pyle H. R. Dean R. L. Beeth J. D. Parsons R. L. Waldrop A. J. Granger R. A. Frazar M. D. Scwharz Baker & Botts) '

R. Gordon Gooch Baker & Botts)

J. R. Newman Lowenstein, Newman, Reis, Axelrad & Toll)

Director, Office of Inspection & Enforcement

- Nuclear Regulatory Connission Washington, D. C. 20555 M. L. Borchelt

• Executive Vice President \

Central Power & Light Company l P. O. Box 2121 Corpus Christi, Texas 78403 R. L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, Texas 78403 )

R. L. Hancock Director of Electrical Utilities City of Austin P. O. Box 1088 Austin, Texas 78767 ,

T. H. Muehlenbeck

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City of Austin P. O. Box 1088 Austin, Texas 78767 J. B. Poston  :

l Assistan General Manager of Operations City Public Service Board l

P. O. Box 1771 l San Antonio, Texas 78296 l

t A. vonRosenbera

- City Public Serv'.ce Board P. O. Box 1771 San Antonio, Texas 78296 k

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H..u u.n 1.ighiing A: P.mes ( nmp. ins September 24,1980 ST-HL-AE-541 SFN: C-0510 Page 4 Charles Bechoefer, Esquire Chairman, Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emeth A. Luebke Atomic Safety & Licensing Comission U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Steven A. Sinkin, Esquire 116 Villita Street San Antonio, Texas 78205

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Citizens for Equitable Utilities c/o Ms. Peggy Buchorn Route 1. Box 432 Brazoria, Texas 77422 Fichard W. Lowerre Esquire Issistant Attorney General for the State of Texas I . O. Box 12548 Capitol Station Au.' tin, Texas 78711 Henry 1. McGurren, Esquire j Hearing Attorney Office o,' the Executive Legal Director U. S. Nucitar Regulatory Comission Washington, D. C. 20555 4

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, l 80 82 83 84 85 86 END OF YEAR ATTACllMENT 1

HOUSTON LIGHTING S POWER -

QUALITY ASSURANCE DEPARTMENT d EXECUTIVE ,

VICE PRESIDENT 110USTON SITE OFFICE MANAGER QA Il0USTON QA STP MANAGER 110USTON OFFICE LICENSING SUPPORT

.., PROJECT QA SUPERVISOR l

- Il0USTON HOUSTON OFFICE OFFICE OPERATIONS PROJECTS QA MANAGER QA MANAGER I

DISCIPLINE QA PROJECT QA GEN. SUPERVISOR HOUSTON SITE SITE SITE SITE SITE OFFICE wp QUALITY CONTROL MECil/NDE CIVIL /STRUCT. ELEC/I6C PLANT NDE/ISI PROJECT SUPERVISOR PROJECT PROIECT PROJECT QA SUPERVISOR OPERATIONS QA SUPERVISOR QA SUPERVISOR QA SUPERVISOR QA SUPERVISOR QA SUPERVISOR WAP I

HOUSTON SITF' IIOUSTON 110USTON 110USTON OFFICE 0FFTCF OFFICE OFFICE PROCUREMENT QUALITY SYSTEMS SUPERVISOR SUPERVISOR PROJ ECT PROJECT SUPERVISOR AUDITS & VENDOR QA SUPERVISOR QA SUPERVISOR l'EClINICAL SERVS SURVEILLANCE ALLENS CREEK ATTACHMENT 2