ML19340B365
| ML19340B365 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/24/1980 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8010220216 | |
| Download: ML19340B365 (7) | |
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UNITED STATES y
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- n NUCLEAR REGULATORY COMMISSION 3,
E WASHINGTON, D. C. 20555 e-
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Docket Nos. STN'50-498/499 SEP 2 41980 4
Mr. G. W. Oprea, Jr.
Executive Vice President l
Houston Lighting and Power Company P. O. Box 1700 i
Houston, Texas 77001 l
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Dear Mr. Oprea:
SUBJECT:
QA PROGRAM FOR THE DESIGN AND CONSTRUCTION OF THE SOUTH TEXA5 PROJEC I
Confirming a number of conversations and telephone discussions with your staff, it is requested that you take the following actions relative to the QA program for the South Texas Project.
1.
As soon as pcssible you should provide a revised QA program as summarized in your responsc to the Show Cause Order issued on July 28, 1980, and which addresses the concerns raised by the staff and-responded to by Houston Lighting and Power and Brown and Root during the technical meeting i
held in Bay City on August 19, 1950. This document should also discuss the philosophy behind the new organization and the extent of management comitment to assure the successful operation of this new organization.
It should also include your commitment to fully document this r.ew organi-zation and program and be sent to the Office of Nuclear Reactor Regulation with copies to Region IV and the Office of Inspection and Enforcement.
2.
In documenting this new organization and program formally, you should follow the format of Section 17.1 contained in Regulatory Guide 1.70, Revision 3.
This will materially assist us in our review of this significant revision to your design and construction QA program.
In addition you should address the specific questions contained in the
' enclosure to this letter. This document should be sent to the Office l
of Neclear Reactor Regulation requesting NRC review with copies to l
Region IV and the Office'of Inspection and Enforcement.
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I' SEP 2 41980 The document should also state that it supersedes the previously submitted QA program description and revisions that deal with the design and construction of the South Texas Project. This is in line with our request s
for additional information and instructions gentainec in Question QAB 421.1 of our letter of July 5,1978.
As a result of discussions with your statf, a date of October 15, 1980, has-been agreed to for submittal of the requested document.
If this date cannot be met, please advise me of the reason (s) for delay and a date i
which you feel can be met.
If there are any questions concerning this request, please contact the project manager, D. Sells (301) 492-7792.
Sincerely,
't-- W Robert L. Tedesco Assistant Director for Licensing Division of Licensing Enclosu're:
As stated cc w/ enclosure:
See next page l
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Mr. G. W. Oprea, Jr.
Executive Vice President Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 s
cc:
Mr. D. G. Barker Troy C. Webb, Esq.
Manager,-South Texas Project Assistant Attorney General Houston Lighting and P wer Company Env ironmental Protection Division Q
P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Captiol Station Austin, Texas 78711 Mr. M. L. Borchelt Central Power and Light company R. Gordon Gooch, Esq.
P. O. Box 2121 Baker & Botts Corpus Christi, Texas 78403 1701 Pennsylvania Avenue, N.W.
Mr. R. L. Hancock Washington, D. C.
20006 City of Austin Electric Utility Department Director, Governor's Budget P. O. Box 1088 and Planning Office Austin, Texas 78767 Executive Office Building 411 W. 13th Street Austin, Texas 78701 Mr. J. B. Poston Assistant General Manager for Operations John L. Anderson City Public Service Board P. O. Box 1771 Oak Ridge National Laboratory Union Carbide Corporation San Antonio, Texas 78296 Bldg. 3500, P. O. Box X Oak Ridge, Tennessee 37830 Jack R. Newnan, Esq.-
Lowenstein, Newman, Axelrad & Toll 1025 Connecticut Avenue, N. W.
Resident Inspector / South Texas NPS c/o U. S. NRC Washington, D. C.
20036 P. O. Box 910 Melbert Schwarz, Jr., Esq.
Bay City, Texas 77414 Baker & Botts Mr. R. Jacobi.
One Shell Pla:a Houston, Texas 77002 Houston Lighting and Power Company i
P. O. Box 1700
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Mr. A. T. Parker Houston, Texas 77001 Westinghouse Electric Corporation P. O. Box 355.
Pittsburgn, Pennsylvania 15230 1
Mr. E. R. Schmidt NL'S Corporation NUS 4 Researen Place Rockville, Maryland 20850 l
t Mr. J. R.: Geurts Brcwn &.Rcot, Inc.
P. O. Sox 3 Housten, Texas 77001 i
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ENCLOSURE SOUTH TEXAS PR0'iRAM REQUEST FOR ADDITIONAL INFORMATION O
la.
Submit into the docket of the South Texas Project (STP) Houston Lighting &
Power's (HL&P) and Brown & Root's (B&R) improved QA program controls discussed in the HL&P July 18, 1980 response to the Order to Show Cause dated April 30, 1980 and at the open public meeting August 19, 1980 as a revision to the QA program description pretented in Chapter 17 of the STP Preliminary Safety Analysis Report.
Your re_ponse should clearly indicate that the previously docketed QA program description is superseded by the new submittal, ib.
Provide a commitment in your revised QA program description to notify NRC of changes to the docketed QA program description, for review and acceptance, prior to implementation except for rganizational changes which are to be reported within 30 days af ter annot.acement.
(Note - editorial changes or personnel reassignments of a non-substantive nature do not require NRC notification. )
2.
Provide in your response to item 1 above the additional information requested below which was previously addressed at the public meeting of August 19, 1980.
2a.
Describe, both in descriptive form and through organizational charts HL&P and B&R organization structures relative to the STP with particular emphasis on the QA organizations and their interaction between HL&P and B&R personnel.
2 b.-
As outlined in your response to the Order to Show Cause, dated July 28, 1930, the HL&P organization ' establishes Quality Assurance Supervisors in each of the major disciplines such as civil, structural, and electrical instrumentation. How will each of these HL&P Supervisors provide programmatic direction to Brown & Root on matters related to his discipline? Is it planned to have c direct interface with Brown & Root Quality Engineering of'the same discipline?
2c.
Describe the extent to which QA individuals in HL&P and B&R participate in design and construction daily staff meetings to (a) keep abreast of daily work assignments,.(b) assure adequate QA attention and controls are applied to quality affecting activities, and (c) assure adequate QA/QC staffing is
- available to accommodate daily work assignments and assist in resolving problen areas.
2d.
Describe your QA program for transferring responsibilities and control of quality-related activities from the principal contractors to HL&P during the phase out of design and construction activities.
, 2e.
In your response to the Order to Show Cause you state that HL&P is attempting to improve the attitude of the QA/QC personnel through insistence on adherence to procedures, emphasis on the independence of the QA/QC function, q
and improved supervisory support for the QC inspectors. Describe in greater detail how the development and maintenance of the proper QA/QC attitude will be monitored. What management steps are contemplated should departure in expected performance be identified?
2f.
Provide a matrix of recomendations proposed by Bechtel and MAC and HL&P's evaluation of each recommendation.
In those cases where the recomendations were not accepted, the basis for the rejection should be described.
2.
(1) Describe the extent HL&P will implement Bechtel's recomendations 9
relative to (a) competitive salary ranges for QAEs and (b) ratios of staffing levels for QAEs and QCEs both at HL&P and B&R.
(2) Provide a comparison of new staffing and qualification pla7s for HL&P and B&R relative to the prior situation and describe your criteria for determining when supplementary personnel from MAC are no longer necessary.
2h.
Your response to the Order to Show Cause contains many comitments in a number of quality assurance and construction areas with completion of these commitments over a time span. Describe in detail your system to track and ensure completion of reqaired commitments before recomending restart of work in a particular area.
2i.
You state in the response to the Order to Show Cause that key HL&P personnel are being retrained in basic principles of quality assurance.
Indicate whether this is intended to be a continuing program, also identify who is responsible for administering controling, and evaluating this training.
2j.
(1) In regard to qualification of personnel, describe the criteria for determining when upgraded qualifications are achieved for personnel both within HL&P and B&R. Will proficiency tests be given to person-nel performing activities affecting quality and acceptance criteria developed to determine when an individual is qualified? How and by whom are proficiency tests prepared? Will certificates of qualifica-tion clearly delineate the specific' functions the individual is quali-fied to perform and will they include the criteria used to qualify the individual in each function?
(2) What has been done to verify that personnel, presently on the job, are fully qualified for their positions?
(3) What it being done to upgrade radiograph interpretation capability?
-3 2k.
In regard to upgrading quality assurance actions, you state you are re-writing construction procedures in a format which makes them easier to implement and that already you have revised concrete and welding procedures.
g (1) Will personnel who are to implement the revised procedures have input to the changes? (The lack of input into the June 1978 procedure revisions apparently caused concern among QC inspectors.)
(2) What are your plans with regard to training personnel on these procedures? (QC personnel were concerned when 1978 procedure revisions were hastily implemented without sufficient training.)
21.
In your response to the Order to Show Cause you state that inspectors initiate nonconformance reports as appropriate only during " planned in-spections." Does this preclude an inspector from writing such reports in advance of planned inspection milestones, during surveillance inspections, or when proceeding through the plant? Describe your controls in this area in full detail.
2m.
In your response to the Order tc Show Cause you state that following initiation of a nonconformance report, an inspector must obtain acknowledgement by signature of the Construction Foreman or General Foreman.
State your procedures for covering ir.spector action when such acknowledgement is refused or cannot be obtained? Describe your controls in this area in L
full detail.
2n.
Describe the extent to which authorized individuals, within the HL&P
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and B&R engineering and QA organizations, responsible for determining acceptable dispositions and closecuts of nonconformances are preselected and identified on official documents and state whether the document is used in the nonconformance process.
i 0o.
In your response to tha Order to Rhow Cause, you state that where appropriate, i-hold tags or other work constraints will be applied. The tenn "where appropriate" does not provide us with a sufficient understanding of the degree to which nonconforming items will be segregated and tagged to control further processing or installation. Describe in full detail HL&P and B&R controls in this area.
2p.
Describe in full detail, your controls which will assure that corrective actions are completed in a reasonable time frame.
24 For quality affecting activities, describe the criteria for determining (a) l what inspections are to be performed, (b) the accuracy requirements of measuring and test equipment.
l 2r.
Describe HL&P's and B&R's QA involvement in the documented evaluation of inspection and test results to assure they are complete and accurate.
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2s.
Describe who.within HL&P and B&R is responsible for the calibration of measuring and test equipment including NDT devices and describe the QA organization involvement in this area. Also state that person or i
g persons qualification.
2t.
Describe your controls for documenting and maintainit,g as-built l
conditions on drawings and specifications. Describe the extent as-built drawings and specifications identify nonconformances dispositioned as
" accept as is."
3.
In your submittal of the revised QA program description, provide a means for locating your responses to the above specific reqLests.
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