ML19341A745
| ML19341A745 | |
| 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 | |
| ML19341A601 | List: |
| References | |
| ST-HL-AE-548, NUDOCS 8101270857 | |
| Download: ML19341A745 (8) | |
Text
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O The Light Company n,iisi.,,, ugiiii,o n>m m n.,x noo n.,iis,<,,2.m.xas,ooi aoms.mn September 24, 1980 ST-HL-AE-548 SFN: C-0510 Mr. Kari Seyf rit Director, Region IV Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012 Dear Mr. Seyf t. 4.
South Texas Project Units I&2 Docket Nos. STN 50-498, STN 50-499 Response to Bechtel Pecommendations As requested in the Public Meetin1 of August 19, 1980 and identified as Hl2 in our Ccmmitment List submitted to you on September 18, 1980, this letter with its attachment represents Houston Lighting & Power Company's analysis and response to the Bechtel recernendations.
Should you have any questions please advise.
Very truly yours, 0
s.
madvy'ident
/
Exec M ive M (e Pres j
GWO/ngb Attachment NO12?nQ l
i.
Houston Ughting k Power unnpany September 24, 1980 ST-HL-AE-548 SFN:
C-0510 Pace 2 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. Gordan Gooch (Baker i Botts)
J. R. Newman (Lewenstein, Newman, Reis, Axelrad & 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 Corpus Christi, Texas 78403 R. L. Hancock Director of Electrical Utilities City of Austin P. O. Box 1088 Austin, Texas 78767 T. H. Muehlenbeck City of Austin P. O. Box 1088 Austin, Texas 78767 J. B. Poston Assistan General Manager of Operations City Public Service Board P. O. Box 1771 San Antonio, Texas 78296 A. vonRosenbero City Public Service Board P. O. Box 1771 San Antonio, Texas 78296
_r bouston Lighting & Power Comp.in)
S L E-5 SFN: C-0510 Page 3 Charles Bechoefer, Esquire Chairman, Atomic Safety & Lice 7 sing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Or. Janes C. Lamb, III 313 Woodhaven Road Chapel' Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety & Licensing Commission U. S. Nuclear Regulatory Commission 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 Henry J. McGurren, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regula'.ory Commission Washington, D. C. 20555 M
SOUTH TEXAS PROJECT RESPONSE TO BECHTEL RECOMMENDATIONS I.
Procedures A.
Recommendation:
It is recommended that a task force from both HL&P and BAR be organized for the purpose of reviewing functional 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 commitments. The Consteuction procedures are reviewed by Design Engineering.e 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 restruc turing.
B.
Recommendation: HL&P QA should coordinate and track the task force effort.
Response: HL&P QA is working closely with B&R and is tracking the results and progress of the procedure rewrites.
C.
Recommendation: A matrix should then be structured to identify how requirements and commitments are met by functional procedures.
Response: The use of a matrix is under review.
It would come into use af ter procedures have been revised.
D.
Recommendation: Once the functional procedures are in place, a six-mor.th 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 Recommendation:
It is recommended that HL&P and B&R management commit to prudent action for documenting trends of nonconformance and program deficiencies identified by audit results.
Response: A trend analysis program for nonconformance identified 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 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 functions s 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 Lighting & Power Company.
B.
Recomendation:
It is recommended that quality orientation and indoctrination programs involve HL&P and B&R personnel at all 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 being addressed as part of the training programs for both Brown & Root and Houston Lighting & Power Company.
D.
Recommenda tion:
It is further recommended that consideration be given to prograns 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 Houston Lighting & Power and Brown & Root personnel.
IV. System Controls A.
Recommenda tion:
It is recommendet that the STP QA program and i+s 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 procpdure development effort. Careful planning for eacn construction 2
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.
Recommenda tion:
It is recommended that the i.'R audit system incorporate distribution of audit reports t', 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 internal and site audit reports:
S. H. Grote, Senior Vice President K. M. Broom, Senior Vice President W. M. Rice, Group Vice President B.
Recommmendation:
It is further recommended 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 B&R.
HL&P response: Auditors are being selected based upon the technical requirements of the area being audited.
B&R response: Screening of applicants and greater attention to selection of audit personnel has been implemented. Highly qualified subcontract audit personnel ' nave been added to B&R staff in order to supplement the organizational needs until,'
additions to staff have been completed and qualified. New audit program indoctrination and training have been performed and are ongoing.
D.
Recommendation:
Emphasis should be placed on maintaining accurate qualification records.
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e 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.
B&R response: All personnel files were completely reviewed and updated as required to assure that substantiation of the basis for qualification is documented.
VI. Management Involvement A.
Recommenda"on:
It is recommended that both HL&P and B&R management uke immediate steps to demonstrate their commitment to quality performance and their unequivocal support of the STP QA program.
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. Ric2's address to some 600 Brown & Root employees in whi, h he stated unequivocally the support of the QA program. Additionally, Mr. Oprea's meetings with the project team and the performance of both managements in the public 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.
Recommendation:
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 noted weaknesses.
C.
Rccmmendation: The respective QA functions of HL&P and B&R should be examined to ensure independent yet complementary QA practices.
Response: The quality assurance functions of Houston Lighting & 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 programmatic implementation by Brown & Root have ensured independent but complementary QA practices.
Implementation of this philosophy is ongoing.
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D.
Recommendation:
It is recommended that a management information system and a closed-loop management corrective action system be initiated for the purpose of advising HL&P and B&R management of conditions adverse to quality and for ensuring that timely corrective action is taken.
Response: Under development is a system of repo' ting to management which calls for regular nonconformance trend summaries, audit summaries, and QA activity reports.
In addition, management is attempting regular meetings on site to be apprised of the status of the quality assurance program. The nonconformance and corrective action systems provide for planned work constraints and management intervention if timely corrective action is not achieved.
E.
Recommendation:
It is recommended that B&R management initiate a system of periodic maragement reviews.
Response: A system of periodic management reviews has been established by Brown & Root senior management in the manner of the quality assurance Management Review Board attending the monthly project quality meeting wherein functional groups on the project are represented by ma::agement level personnel, ard q:'ality problems and solutions are discussed at these meetings. Additionally, in HL&P Mr. Oprea has spent an average of two days per week at the site reviewing progress, problems and status of the quality assurance program implementation, as well as construction activities.
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