ML19341A761
| ML19341A761 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/22/1980 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19341A760 | List: |
| References | |
| ST-HL-AE-545, NUDOCS 8101270924 | |
| Download: ML19341A761 (13) | |
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September 22, 1980 ST-HL-AE-545 SFN: V-0110 Mr. Karl Seyfrit Director, Region IV Nuclear Regulatory Commission 611 Ryan Pla:a Drive, Suite 1000 Arlington, Texas 76012
Dear Mr. Seyfrit:
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South Texas Project Units 162 Docket Nos. STN 50-49S, STN 50-499 Weldinc and Concrete Programs During our mee*ing on September 12, 1980, you requested additional information relative to the reexamination, repair, and restart of safety-related welding, concrete restart plans and schedules, and interim controls for NCR's and FREA's on the South Texas Project. The attached package contains documents which:
1.
Define the scope of reexamination that will be performed.
2.
Summarize the activities planned, where these activities will be performed, and the schedule for initiating these activities.
i 3.
Describes the welder incentive pay program established for for the project.
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4.
Describe Concrete Restart Plans.
5.
Describe interim controls that are in place to process NCR's and FREA's until the new systems are implemented.
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Describe improvements in our welding program.
1 Attachment II, the "Reexaraination, Repair, and Nelding Restart Plans" submitted to you by our letter of September 10, 1980, has been revised (Rev. 1, September 8, 1980) to incorporate Items 1 and 2 above.
Item 1 is presented as a Forward to the plan.
Item 2 has been incorporated as Tab 7 of the plans and a description of the welder incentive program, Item 3 above, has been incorporated as Tab S.
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Houston Lighting & Power Compam Mr. Karl Seyfrit September 22, 1980 ST-HL-AE-545 Page 2 Please discard the portion of the earlier September 10, 1980, submittal identified as Attachment II, " Reexamination, Repair, and Welding Restart Plans." The other attachments to the September 10, 1980 submittal,
" Attachment 1-Interim Report Review of Safety Related Welding," and "STP-PGM-12 Rev. O h'elding Program Description" are still valid, 1
Item 4 is presented in the enclosed document titled " Concrete Restart Program" - Rev. O, September 18, 1980. This attachment provides the details of our implementation of certain commitments in order to resume i
complex safety related concrete pours.
Included are discussions on training, i
schedules, and documentation packages.
l Item 5 is contained in the enclosure titled " Interim Non-Com-pliance and FREA Systems". This attachment provides an outline of the interim system including review cycles and approval authority.
Item 6 is contained in the enclosed document titled " Summary of i
STP Welding Program Improvements".
i Should you have any questions concerning these documents, please advise.
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l Very truly yours,
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- h., r Exec ivee"ce President DGB/cmd Att hments i
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Houston Lighting & Power Company 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 Commission Washington, D. C. 20555 M. L. Borchelt Executive Vice President Central Power & Light Comoany 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
T. H. Muehlenbeck City of Austin P. O. Box 1083 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
Homion Lighting & Pimer Compam Charles Bechoefer, Esquire Chairman, 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 1
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 V. S. Nuclear Regulatory Commission Washington, D. C. 20555 l
SUMMARY
OF STP WELDING PROGRAM IMPROVEMENTS i
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SUMMARY
OF STP WELDING PROGRAM 1rtPROVEMENTS I.
Welder Training Programs The welder training programs have been reviewed and upgraded.
Training criteria have been established to cover five areas of proficiency:
1.
New hires inexperienced 2.
New hires experienced 3.
Presently employed upgrade 4.
Presently employed having difficulty with certain processes b.
Presently employed with occasional difficulties The training associated with these five areas is summarized in paragraph 6.2 of the STP Welding Program Description.
II.
Incentive Program The welder incentive program has been established for high pro-ficiency nuclear grade welders. The program is described in tab 8 of the document describing the re-examination, repair and welding restart plans.
III. Construction Procedures Construction procedures related to welding activities have been reviewed and revised. Welding requirements are clearer and more concise. These procedures are identified in the welding document matrix table 5-1 of the Welding Program Description.
IV. Welding Supervision Welding supervision on the project has been upgraded by the addition of experienced welding supervisory personnel by hiring and transfers from other projects. A welding group has been established in the construction organization and is responsible for supervising all construction welding activities. Typical qualifications and duties of welding supervisors are listed in paragraph 4.5 of the Welding Program Description.
V.
Welding Engineering Staff The project welding engineering staff has been upgraded by the addition of experienced welding engineers and welding technicians.
The functional responsibilities of the welding engineering group are clearly defined in paragraph 3.3 of the Welding Program Description.
VI. Walding Material Control Procedures for controlling welding materials has been reviewed and revised. Specific requirements are clearer and more concise.
Specific responsibilities for controlling welding materials has been assigned.
VII. Welding Proficiency Tracking The procedure for tracking and evaluating welder proficiency on a continuous basis has been revised. Paragraph 6.4 in the Welding Program Description describes the procedure.
VIII. Welder Repair Rate Tracking The procedure for tracking weld repair rates on a continuous basis have been revised. The requirements are clearer and more concise.
Paragraph 7.2 of the Welding Program Description describes the methods.
IX. Automatic Welding The use of automatic welding equipment and procedures will be expanded as far as practical.
X.
Exchange of Information An informal system will be implemented to exchange welding related information and gain experience from other Brown & Root projects.
XI. Welding Program Descriotion Welding program description has been prepared and issued to all cognizant construction, engineering and QA personnel on the project. Some advantages of this document are:
1.
It compiles and describes all welding related programs in one document.
2.
It identifies the elements needed in order to consistently produce sound welds.
3.
It addresses how each of these elements is attained.
4.
It identifies the documents and procedures related to welding on the project.
5.
It identifies the organizations and individuals responsible for implementing the welding program.
6.
It provides a document for pinpointing the specific activities or procedures for review.
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XII. Attitude Improvement The attitude of the individuals associated with welding have been improved through fonnal and informal meetings and discussions.
The zero defects concept has been introduced at both supervisory and craft levels. These discussions and meetings will continue throughout the construction of the pmject.
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INTERIM NON '.0NFORMANCE AND FREA SYSTEMS
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INTERIM NON-CONFORMANCE SYSTEM The interim non-confermance system has been in effect since July 31, 1980 when we recom= ended resumption of AWS Welding. This system is in compliance vita the existing Procedure ST-QAP-2.6 Nonconfor-mance Control but reinforced with better control.
The interim system shortens the time cycle for review and implementa-tion by combining several actions, as follows:
1.
The inspector writes the non-conformance (not a draf t) and affixes ' Told Tags",
(a) The required condition and the actual condition of the non-conformance is accurately stated.
(b) The construction drawing related to the non-con-forming condition is documented, if applicable, and (c) All necessary sketches or supporting documentation is attached.
This system was emphasized in a General Training session presented by L. E. Zwissler, July 18, 1980, prior to the initiation of the interim system.
2.
For rework or standard repair the NCR can be dispositioned by the Lead Inspector and the Construction Foreman.
(a)
The completed NCR is forwarded to QAE when rework /
repair is acceptable for review then sent to the QA Vault for_ storage.
Permitting rework / standard repair decisions at the source has developed a good working relationship between the Construction Supervision and Inspection.
3.
Where "Use-As-Is" or repair is necessary the NCR is sent to-QAE for review.
j (a) QAE sends the NCR to the Material Review Board where all concerned organizations participate concurr,ently in the disposition.
4.
QAE and Construction prepare plans to implement the disposit-ion, then issue their plans to construction to perform work.
(a) The work is completed and reinspected.
(b) The NCR, af ter close-out, is reviewed by the QE for com-pleteness and then sent to the QA' Vault.
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The Quality Engineering Section has played an important role in the Non-conformance System. They have supplied the technical direction in support of Quality Control. They have presented the training classes to better understand the system. They have developed a rapport with QC to plan the inspections at convenient points to accommodate the work activity.
The new f eature of the program is establishing the Materials Review Board (MRB) as an additional administrative control over non-confor-mances. The MRB will be an on-site committee consisting of represent-ative from B&R Project General Management (PGM), QA, Design Engineering and Construction. The MRB will be responsible for providing disposi-tions to all NCR's requiring design evaluation. The MRB is not a com-mittee that acts by a majority; the concurrence of each member is re-quired for disposition of an NCR. The MRB members will prepare the proposed disposition based on consultation with their respective organ-izations. When the MRB members concur on the disposition each member signs the NCR. When the MRB review has been completed, the signed NCR, with disposition noted, will be sent to construction for implementation and to QC for inspection.
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INTERIM FIELD REQUEST FOR ENGINEERING ~
ACTiDN (FREA) SYSTEM The interim system used to control Field Requests for Engir.eering Action (FREA) is basically the same system as outlined in Project Procedure STP-GPM-03, Rev.1, STP-DC-023, and A040KFGCP-21, with the additional following controls applied:
1.
Additional controls have been added to ensure that FREA's are not used to identify nonconformances. The Assistant Engineering Project Manager-Site has been instructed to reject any FREA that, in his opinion, represents a nonconformance.
In addition, FREA's are signed by the Quality Assurance Engineers to ensure that they do not convey nonconformances.
2.
FREA's are reviewed b: the Engineering organization of the Houston
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Lighting & Power Company.
3.
Additional reviews are conducted on each FREA to ensure that the affect of the change on the design has been assessed. A special form has been provided for this review. A copy of this form is attached. This form must be completed by the Engineering orgar.??.a-tion as parx af the design verification of the FREA. This form is then reviewed by the Discipline Project Engineer, Design Quality Engineering, and the Engineering Project Manager.
This form will become part of the record file for that design document. This review has been conducted on all FREA's approved subsequent to the l
date of February 29, 1980 as part of the FREA review and approval activities. All FREA's issued prior to that date will be reviewed in the same manner on a " post approval" basis.
4.
The rules concerning the approval of FREA's as one-time deviations are being strictly enforced.
The majority of FREA's are being approved as design changes via the DCN (Document Change Notice),
instead of being approved as deviations.
The strict enforcement of these rules in addition to close Management attention, has provided the controls needed to assure that the problems that had occurred with those FREA's issued prior to this time had not l
recurred.
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a FREA REVIEW FORM FREA NUMBER DOCUMENT NUMBER DISCIPLINE OFS:GN AFv FW g
QUAtfTY REVIEW gg 1 WAS CORPECT DOCUMENT REFERENCED?
1 WAS THE DOCUMENT LEGI8LE AND REPRODUC18tE) 2 IS REFERENCED DOCUMENT SAFETY RELATED?
IF NO. ATTACH REPRODUCIBLE COPY 3 WAS BASIS FOR APPROVAL DOCUMENTED ON THIS 2 WAS FREA CONTROLLED IN ACCORDANCE WITH FREA PROJECT PROCEDURES ?
IF YES. If IS ADECUATE P IF NOT ADEQUATE. THEN IF NO UST EOD NUMBER IN SPACE PROVIDED BELOW PROVICE ADDITIONAL INFORMATION BELOW JF NO. PROVt0E BASE IN SPACE PROVIDED BELOW.
4 WAS B&R CALCULATION CONSULTED AS PART OF THE
- 3. IF E00 WAS ISSUED. LIST CLOSEOUT DATE IN THE BASIS FOR APPROVAL)
SPACE PROVIDED BELOW.
IF YES. LIST TPNS NO IN FOLLOWING SPACE
- 4. ENTER THE FOLLOWING INFORMATION WHICH WILL 8E USED AS A 8 ASIS FOR ENCOOiNG DATA INTO FREA TRENDING PROGRAM IF (ES. AND CALCULATION WAS REVISED. PROV10E THE RE/ISION INFORMATION 6N FOLLOWING SPACE UNIT SUILDING IF NO. WAS UNUSTED CALCULATION PERFORMEDP SUBJECT CODE IF SO, ATTACH COPY.
REMARKS 5 WAS THIS CHANGE INCORPORATED INTO REFERENCE DOCUMENT)
.F YES. UST DOCUMENT NO AND REVISION LN SPACE PROVIDED BELOW
- 7. 00Eb THIS CHANGE AFFECT ANY OTHER DOCUMENT OTHER THAN FSAR OR DESIGN MANUALP IF YES. UST REVISION BELOW INTERFACING DESC!PUNE SIGNATURE 8 ALARA REVIEW REQUIRED SIGNATURE 9 DESIGN VERIFICATION S6GNATURE RAME (PRINTED SIGNATURE DATE NAME (PRINTED SIGNATURE OATE 8ASES FOR FREA DISPOSITION r
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FREA REVIEW FORM INSTRUCTIONS DESIGN REVIEW 1.
IF CORRECT DOCUMENT WAS NOT REFERENCED, CORRECT FREA FORM BY STRIKING THROUGH INCORRECT REFERENCE AND!OR ADDING CORRECT REF2RENCES.
2.
IF THE REFERENCE DOCUMENT WAS SAFETY RELATED. THE FORM MUST BE SIGNED BY A DECfGN VERIFIER. lF iT HAS NOT BEEN. SUCH A SIGNATURE WILL BE OBTAINED FOLLOWING COMPLETION OF THE LEFT COLUMN OF THIS FORM.
3.
THE ADEQUATE BASES WAS NOT PROVIDED,IT MUST BE WRITTEN IN THE FORM UNDER " BASES FOR FREA DISPOSITION" 4.
IF PURPOSE OF THIS FORM IS TO PROVICE FOR TRACEABILITY TO CALCULATIONS OR. IF
" INFORMAL" CALCULATIONS WERE USED. ENSURE ?!;Ei ARE ATTACHED TO THIS FORM
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5.
IF THIS CHANGE WAS INCORPORATED INTO TriE F EFERENCE DOCUMENT, EiTHER AT THE TIME OF l
APPROVAL OR LATER. IDENTIFY REVISION NO. AND DATE OR DCN AND DATE.
6.
IF THIS CHANGE EFFECTED THE DESIGN M'4NUAL OR FSAR COMMITMENTS. lDEATIFY THE METHOD OF REVISING DESIGN MANUAL OR FSAR (SUCH AS REVISION, DCN, OR GM NO.). IF THIS HAS NOT BEEN DONE AND IS REQUIRED, IT MUST BE COMPLETED PRIOR TO SUBMITT'NG THIS FORM TO QUAUTY ENGINEERING.
7.
IF THIS CHANGE EFFECTS ANY DOCUMENT THAT IS THE RESPONSIBILITY OF ANY DISCIPLINE, THE CHANGE WILL EITHER BE LISTED HERE IF COMPLETED OR,IF NOT COMPLETED. LISTED AFTER THE l
REVISION HAS BEEN APPROVED. OBTAIN THE SIGNATURE OF THE INTERFACING DISCIPLINE DPE.
8.
OBTAIN THE SIGNATURE OF THE ALARA REVIEWER. IF REQUIRED BY STP-DC-016.
l 9.
IF THE REFERENCED DOCUMENT REQUIRES DESIGN VERIFICATION ACCORDING TO STP-DC-015 OBTAIN DESIGN VERIFIER'S SIGNATURE.
QUALITY REVIEW 1.
IF THE DOCUMENT IS NOT LEGIBLE AND/OR REPRODUCIBLE. A NEW DRAFT MUST BE TYPED AND SIGNED. IT WILL BE ATTACHED TO THE ORIGINAL FOR RECORD PURPOSES.
2.
IF THE FREA WAS NOT APPROVED IN ACCORDANCE WITH PROJECT PROCEDURES, AN EDD MUST I
BE ISSUED.
3.
THE ABOVE EDD MUST BE CLOSED OUT PRIOR TO RETURNING THIS FORM TO EDCC.
4.
ENTER THE FOLLOWING INFORMATION.
THE NAME (PRINTED). SIGNATURE. AND DATE WILL BE ENTERED BY THE DESIGN ENGINEER AND THE QUALITY ENGINEER DOING THE REVIEW.
THE BASIS FOR THE FREA DISPOSITION WILL BE ENTERED IF THE ANSWERS TO 3 ARE NO OR YES/NO.
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