ML19343D374
| ML19343D374 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Briskin J HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19343D370 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8105040354 | |
| Download: ML19343D374 (59) | |
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4i TESTIMONY OF JOSEPH W. BRISKIN 5l ON HL&P'S TASK FORCE APPROACH TO RESPONDING TO THE NRC ORDER TO SHOW CAUSE 6
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8l 9l Q. 1 Please state your name and current occupation.
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A.
1 I am Joseph W. Briskin.
South Texas Project 1 2 '.
13 l (STP) Manager, Houston Operations, of Houston Lighting &
14 15 Power Company (HL&P).
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Q. 2 What are your responsibilities as Manager, Houston 1g'
{g l Operations?
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A. 2 I am responsible for directing the work of the 2
22 components of HL&P's Project Management Team that are located 23 24 '
in Houston.
This includes engineering, procurement, project 25 26 i control services, accounting and project administration.
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23 i Q. 3 Describe your professional experience in construction 29 '
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project management and control.
3{9 l A. 3 I have been actively engaged in project control 3
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34 l and project management for twenty years, including about ten 35 l years on nuclear projects.
This includes four and a half l
37 years as supervisor of project planning and scheduling for 38 -,
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Florida Power & Light Company, where my responsibility 40 41 !
included the St. Lucie and Turkey Point nuclear plants.
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43 f also was employed by Westinghouse Corporation for three and 44 45 a half years as Manager of construction scheduling on Consolidated
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46 47 Edison Company's Indian Point nuclear plant.
I have held my 48 l present position since I joined HL&P in March of 1980.
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8105040354
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Q. 4 What is the purpose of your testimony?
5i A. 4 The purpose of my testimony is to describe the 6I 7{
organization and functioning of the Task Force I headed that 8l 10 l reviewed the NRC Investigation Report No. 79-19 and the NRC 9
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Show Cause Order, and developed the HL&P responses to such 12 i 13 :
order.
My testimony will show how the Task Force systematically 14 13 '
analyzed the issues posed by the NRC Order to Show Cause 16 17 dated April 30, 1980, (Show Cause Order), performed thorough 15 yg j studies of the adequacy of the safety-related concrete, 20 l structural backfill and welding at STP, and designed effec-22 '
tive revisions of the administrative controls for the quality 23 i 24 :
assurance (QA) program.
The details of the results of the 25 '
26 l Task Force work responding to Item 7 of the Order (control 27 l 28 !
of field design changes) are contained in my testimony, 29 !
30 while all of the other detailed results are presented in the 3~1 I
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testimony of the various witness panels on the welding, 3
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concrete and backfill, and in Mr. Frazar's testimony on the 34 35 '
revised administrative controls.
My testimony will also t
36 2' I describe the control system HL&P has adopted to assure that l
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the resulting commitments made by HL&P are fulfilled on a l
40 41 timely basis.
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Q. 5 Describe the Task Force approach to preparing the 44 45 response to the Show cause order.
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4 A.
5 The NRC enforcement action in April of 1980 56j in luded both a Notice of Violation and a Show Cause Order.
The answer to the Notice of Violation was due in 25 days and 9i the response to the Show Cause Order was due in 90 days.
To 10 i 11 !
investigate the twenty-two items of noncompliance and prepare 12 l 13 l a response within 25 days required an intensive effort.
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Mr. Frazar was given responsibi?.ity for the investigation, 16 17 l which he conducted with the aid of the HL&P Houston-based QA 9g!
{g l audit staff headed by Mr. Robert Ulroy.
2 After HL&P filed its response to the Notice of Violation, 2
22 I we had a little over 60 days left to analyze the Show Cause 23 24 l Order, organize the efforts necessary to examine the adequacy 25 ;
26 l of the backfill, concrete and welding, to study alternative 27 '
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administrative controls and to develop revised systems.
To 29 I 30,
perform so much work thoroughly and carefully in that amount 3s i 3{ j of time required that special attention be given to the 33 ll task.
It was recognized that this effort had to be given 34 35 l highest priority, that it would require personnel of the 36 t 37 !
highest qualifications and that the people working on the 38 !
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response should be relieved of all other duties that could 40 41 keep them from devoting adequate time to the Show Cause 42 i 43 response.
44 43 l I was placed in charge of the effort, and I organized a 46 '
47 Task Force of senior HL&P and Brown & Root (B&R) employees 48 49 i
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3i4j and consultants to do the necessary work.
The Task Force 5i was assigned responsibility for preparing draft responses to 6!
eight of the ten Show Cause Order items.
Responsibility for 9!
drafting of responses to Items 1 and 4, regarding QA organiza-10 ;
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tion and the QA brochure was assigned to the QA group, 12 l 13 '
headed by Mr. Frazar.
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Q. 6 Why were you selected to head the Task Force?
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17 l A. 6 The primary role of the Task Force leader was to
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1 gj provide management direction in order to assure that the 20 Task Force effort was given proper priority, that the people 21 ;
22 working on the Task Force were functioning properly and that 23 24 the work was proceeding on schedule.
My position as Manager, 25,
26 l Houston Operations was an appropriate one to head the effort 27 l 28 '
because I had sufficient authority to direct the proper 39 30 !
allocation of resources to the Show Cause response, and to 31 assign additional personnel to the Task Force as the need 32 33 i
might arise.
34 Q. 7 Who assisted you on the Task Force?
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A. 7 The eight Show Cause Order items that were my 38 1
39 responsibility were divided into two areas:
examination of 40 the adequacy of completed construction work and revision of 41 42 l
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certain administrative controls.
We designated Mr. James 44 i
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Hawks, the B&R Engineering Project Manager, to direct efforts 46 in the first area:
Items 2, 3 and 10 dealing with the 47 48 49 l
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3 completed construction work and the FSAR statements regard-4 5
ing backfill placement.
The group working on Items 5 through 71 9, which dealt with Project administrative controls, was 8!
9l under Mr. Robert Ulrey, then HL&P's Supervisor, QA Support 10 !
11 l Division.
12 l 13 l Q. 8 How did you organize the work under Mr. Hawks?
14 A. 8 Under Mr. Hawks, we set up a separate subgroup 13 ;
16 17 l f r each f the three disciplines, backfill, welding and sg' p
concrete, each headed by the Lead 3&R Project Engineer for g
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that area.
These were Mr. Gerald Murphy for concrete, Mr.
99 2b Bernt Pettersson for backfill and Mr. N. J. Natarajan for 23 24 welding.,Each of these men was assigned a sufficient number 25 26 of B&R and HL&P personnel trained in the respective disci-27 28 Pline to perform in-depth studies of the completed work.
In 29 addition, we decided to obtain the services of prominent l
30 33 33 consultants in each of the three areas so that we would have 33 independent assurance that our investigative programs were 3,
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30 well conceived and that the results of our investigations l
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were correct.
Thus, we obtained the services of three l
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39 experts in geotechnical engineering, three experts in non-40 l
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destructive examination of welds and three experts in various 42 ;
43 aspects of the examination of concrete placements.
We also 44 hired a statistician to advise the subgroup working on 45 1
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concrete verification.
In all there were approximately 120 47 l 48 i
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B&R'and HL&P engineers and consultants, and over 150 techni-5i cians and craftsmen, working on these three Task Force 6
f efforts.
The results of the work of these groupL is dis-9!
cussed in detail in the testimony of our witnesses on concrete, 10 i 11 I backfill and welding.
12 13 Q. 9 Describe the organization of the group on admini-14 15,
strative controls working under Mr. Ulrey.
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17 l A. 9 Mr. Ulrey's group had responsibility for show 16 '
yg j Cause Order Items 5 through 9.
It was clear that the primary "O i
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effort in this area was required for Items 6 and 7, which 22 l involved the related systems for reporting of nonconformances 23 '
24 p and for field design changes.
We established a subgroup on 25 26 those areas under Mr. Richard Peverley, the B&A Assistant 27 !
29 1 Engineering Project Manager-Special Services, whose project 29 I 30,
responsibilities routinely include the QA requirements of 31 32 j engineering design.
Mr. William N. Phillips, then HL&P's 33 j Project QA Manager, was responsible for Item 5 on stop work; 34 ;
3 Mr. R. J. Purdy, B&R's QA Records Control Manager was put in 37 charge of the efforts to respond to Item 8 on records control; 38 !
39 i and Mr. Paul W.
Ratter, an experienced HL&P QA Specialist, 40 :
41 I in the audit group was given responsibility for the work on 42 4 43 !
Item 9 on audit programs.
In each case we designated suffi-I 44 45 cient qualified personnel to thoroughly analyze the issues 46 i l
47 I and design workable systems.
We also obtained the advice of A
48 l consultants.
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4 Q. 10 You mentioned that the subgroup headed by Mr.
5 Feverley was a p ertic:larly important part of Mr. Ulrey's 6
7i effort.
How was Mr. Peverley's subgroup organized?
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A.
10 Mr. Peverley was responsible for Items 6 and 7, 10 11 '
which dealt with two related systems, nonconformances and 12 13 field design changes.
Under Mr. Peverley separate teams 14 15 were set up for the two items.
96 17 The responsibility for Item 6 was divided into two 17'
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distinct teams: one for nonconformances reporting and another 2
f r trend analyses.
In each instance the team was composed 21 22 of personnel intimately familiar with the subject being 23 24 reviewed.
Tb3 team reviewing the nonconformance reporting 29 26 (NCR) system was initially headed by Mr. E.
C. McKenney, a 27 ;
23 member of the Engineering Site group.
Mr. McKenney has 29 30 considerable experience in the use of the NCR system.
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Mr. Donald Harris of Management Analysis Corporation, who is 33 n w the advisor to the B&R Quality Engineering Manager, was 34 j
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a consultant to the team.
The representatives of the Engineer-36 37 i ing and Construction organizations were Mr. A.
S. Goewey 38 39' an'd Mr. B. N. Kesarinath, both of whom also have had exten-40 :
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sive experience in Ising the NCR system.
Mr. Ulrey partici-42 l
43 pated in many >f the team's working meetings.
This team 44 l l
45 included not only representatives of the major B&R organiza-46 47 tions that utilize the system, but also included individuals 1
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whose broad experience with the system encompassed several 5
organizational perspectives.
6 The team reviewing trend analysis was headed by Mr. B. F.
9' Mitchell who is a member of the B&R Engineering (Design 10 11 -
Quality Engineering) organization.
Mr. Mitenell has extensive 12,
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experience in reliability analysis and statistical evaluation, 14 15 both of which apply to trend analysis.
Mr. Mitchell was 16 ;
assisted by several members of the B&R Engineering and QA 17 15 '
19 organ 1:ations.
2 After both of these teams had completed their initial 32 studies and had provided recommendations for the reorganiza-23 24 tion of these tasks, this work Jas turned over to Mr. R. A.
25 26 Frazar and Mr. L. Zwissler of Management Analysis Corporation 27 23 who, with the assistance of various members of the EL&P and 29 30 B&R QA organizatior.s, completed the task.
39 35 The team reviewing the field request design change 33 -
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system was headed by R. W. Peverley, who has extensive 3h experience in quality programs and reliability analyses on t
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various projects.
38 39 i Q. 11 How were all of the groups comprising your Task 40 l 41 l Force directed to perform their tasks?
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11 Each grcup was instructed to analyze its area of 44 45 !
respu.
cility, to identify the underlying NRC concerns and 46 to determine any additional aspects of the respective systems 47 i
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that might be improved.
In some of the areas there were 5-6j findings in the NRC Investigation Report which clearly 7!
indicated the problem as perceived by NRC.
In other areas 8
i 9i we were less sure of the problem perceived by NRC.
With 10 I 11 respect to administrative controls, most of the NRC concerns 12 13 !
had been identified during the exit interview in January 1980, 14 15 and studies and procedure changes had already been initiated.
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17 i Each group was directed to go beyond the findings
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1 gj identified by the NRC staff and to determine the necessary 20 improvements.
A good example is the NCR system.
It appeared 32 I to us that the primary NRC concern was that the trend analysis 23 !
24 l on the Project was ineffective.
Mr. Frazar's testimony goes 25 26 l into the purposes and procedures for trend analysis, and I 27 !
28 i will not attempt to duplicate his discussion.
The point I 29 l l
30 j want to make is that we completely reexamined the NCR system 31 i 32 l and proposed changes to improve the system and make it more I
33 l responsive to the needs of the Project organizations.
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similar approach was used by each of the groups.
As a 37 result, we have made significant improvements in our administra-38 ;
39 l tive controls, as Mr. Frazar's testimony explains in detail.
40 41 Q. 12 Were all of the recommendations of the Task 42 l l
43 Force concerning administrative controls accepted and adopted?
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12 Every recommendation was carefully examined by 46 HL&P and B&R management with the aid of consultants.
Most 47 48 j
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2 3i of the recommendations were adopted but the management 4I 5i review did result in changes to some of the proposed new 6i procedures.
The primary changes were in the response to 9i Item 6.
One example concerns the forms used.
The Task 10 l 11 '
Force recommended the adoption of three new forms, to be 12 '
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called an Inspection Report, a Squawk and a Discrepancy 14 15 Report.
Th3se forms would be used to identify concerns 16 about construction work and to escalate the level of review 17 1
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if resolution could not be achieved at the QC Inspector-20 Construction Foreman level.
Based on the consultant's 21 22 advice the system was simplified; a single NCR form is used 23 24 instead of the three forms proposed by the Task Force.
- Also, 25 26 the initial level for resolution of NCR's was changed from 27 ;
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the level of QC Inspector-Construction Foreman to the level 39 30 '
of Lead QC Inspector-Construction General Foreman.
This 39 33 eliminated a potential source of friction between QC Inspec-33 tors and Construction personnel.
This simplified the process, 34 i 35 but retained the essential features of the system proposed 37 :
by the Task Force.
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t 39 In general, however, the management review found the 40 i 41 '
Task Forco proposals to be well conceived, and the basic 42 43 l
changes proposed by the Task Force were adopted and imple-44 i 45 i
mented on the Project.
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4 Q. 13 How were the results of these Task Force and 56l management reviews documented?
w Sl A.
13 HL&P submitted its written response to the Show 3
9 Cause Order on July 28, 1980.
That response described the 10 l 11 studies undertaken regarding the backfill, concrete and 12 l 13 welding, as well as the changes to be made in the QA organi-14 15 sation, personnel and staffing, and in the administrative 16 17,
controls.
These changes involved many procedure revisions.
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Work had already been started on those changes well before 2
the July 28 response was submitted.
22 Q. 14 Item 7 of the Order required that EL&P develop 23 34 and implement a more effective system to provide for the 25 26 control of field changes in order to assess the impact of 27,
28 these changes on the design.
Please explain the meaning of 29 '
30 the term " field change".
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A.
14 A field change is a change in the plant design 33 3 4 ';
that is initiated by a request from the job site.
That does 35 l not mean that the construction crew changes the plant design; 36 i l
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it does not.
It means that construction identifies to 38 39 Engineering a design detail that is difficult or impossible 40 i 41 '
to build exactly as designed.
One example is an interference.
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The designer may have required that a concrete wall have t
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45 l vertical steel reinforcement bars (rebar) throughout its 46 ;
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length at specified intervals.
At the same time, the design 48 i 49 '
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4l may also require that a pipe pass through that wall at a 5!
6i particular point.
If it happens that rebar is located 7l 8l just where the pipe should go, that is an interference which 9i LO l was not anticipated by the designer.
Procedures are LL i (2
provided for Construction to notify Engineering of such
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situations so that the design may be changed, perhaps by 13 moving the pipe, or by moving the rebar.
L6 L7 Q. 15 At the time of the NRC investigation, what was L5 '
L9 the procedure for control of design changes?
20 21 A. 15 Under the procedures in effect at the time of 22 g3,
the NRC investigation, the B&R construction forces and the 14
{g HL&P start-up organization utilized a form entitled " Field fk,
Requests for Engineering Actions" (FREA) to propose design
.1 28 changes from the field.
The FREA was partially filled out 29 30 by C'onstruction personnel and transmitted to B&R Engineering.
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Engineering, if it approved of the design change, would 53 34 !
complete the balance of the FREA.
The completed FREA form 35 !
could serve as the design change mechanism or the change 16 i
could be made on a Document Change Notice.
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The FREA was also used by B&R Engineering to document l
l 10 t 11 design changes or deviations that could not readily be 12 '
l 13 l incorporated on the design drawings, and other minor design 14 ;
15 l changes that did not appear to merit implementing the proce-16 17 dure for issuing a Document Change Notice.
Deviations from l
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4 design could also be approved by procedures involving an 5
NCR.
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Q. 16 What changes were made in response to the NRC 8:
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Order?
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A.
16 The field design change system has been changed 12 i 13 in a number of respects to provide more follow-through 14 13 information to the QC Inspectors; to enable more rapid and 16 17 i efficient determinations through enhanced engineering staffs 13
{g at the site; and to require complete documentation, including 20 justification of all change requests.
These changes include:
31 22 (1) revision of the forms utilized for design changes; 23 >
24 (2) an enhanced on-site B&R Engineering staff; (3) addition 25 26,
of a B&R Engineering board, the Change Review Board, to 27 ;
28 review design changes; and (4) establishment of a design 29 '
30 change tracking system.
Each change is discussed in the i
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remainder of this testimony.
All of this enhances and 4l facilitates the assessment of the individual and cumulative 35 i impact of field changes on the plant design.
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Q. 17 Describe the revisions that have been made to 38 39 '
the design change forms.
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A.
17 To assure that the new system for controlling 42 43 field changes is properly implemented, and to preclude the 44 45 use of field change requests in the place of NCR's to report I
46 47 j nonconforming' conditions, a new system of forms has been 48 i 49 !
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3 4I adopted.
The old FREA form has been eliminated.
Construction f
and Start-up now propose field changes by submitting Field 7'
Change Requests (FCR's) to the Project Site Engineering 8
9 organzation.
i 10 i 11 i An FCR is only used to request a change when a need to 12 i 13,
depart from design requirements is identified in the planning 14 13 i stage or discovered while work is in progress, but prior to 16 '
17 i reaching a planned inspection point.
If a nonconforming 15 !
gg j condition is found to exist during a planned inspection of 20 work, an NCR must be prepared.
An FCR cannot be used as a 22 '
substitute for an NCR; nonconformances are not approved for 23 ;
24 "use-as-is" or " repair" without the filing of an NCR.
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26 i When either the Project Site Engineering organization 27 i 28 ;
or the Engineering office in Houston approves an FCR, it 29 i 30 !
issues a Design Change Notice (DCN).
No such design changes 393] ;
are approved without issuance of a DCN.
The DCN is controlled 33 l; t
ensure that there is objective evidence that all of the 34 l
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essential design control elements -- justification for the 36 j 37 ;
change, engineering evaluation of the change, assessment of 38 j 39 i the effect of the accumulated changes on plant design, 40 41 Change Review Board action, and revision of related documents --
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are sctisfied.
It is the DCN which is reviewed by the 44 i 45 {
Change Review Board and carefully controlled and integrated 46 1
l 47 l into the document control system for as-built verification.
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4l Q. 18 What improvements have resulted from the change of forms?
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A.
la one purpose for changing the forms was to make 8;
9 10 l sure that Project employees fully appreciate the prohibition 11 !
against using the field design change system to get approval 12 '
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for "use-as-is" disposition of nonconformances.
By changing 14 15 the form, and the name of the form, we eliminated the use of 16 17 i the Field Change Request in the same way as the old FREA had
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{g been used.
We also changed the forms to require additional 20 l documentation of the design review process.
Thus we have 22 tightened our controls.
23 24 Q. 19 How well is the new system for field design 29 26 !
changes working?
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A.
19 The new procedures were made effective on October 1, 29 -
30 l 1980.
EL&P has reviewed the content and the rate of generation 3~9 3
of FCR's since then.
The new system was implemented gradually, 33 34 and a few minor procedural adjustments have been necessary.
35 The new FCR and DCN forms have resulted in better documenta-36 ;
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tion of the impact of and justification for design changes.
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39 l Q. 20 What is the function of the B&R on-site Engineering 40 41 l staff?
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A.
20 All design changes proposed at the STP site are 44 i 45 j submitted on an FCR form to the Project Site Engineering 46 ;'
organization,' a staff of Design Engineers located at the 47 48 i 49 i 90 !
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3I 4l site.
This group is led by the Site Engineering Project j
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l 6l Manager, who reports to the B&R Engineering Project Manager.
1 7i The Site Engineering Project Manager is the principal inter-g 9!
face between B&R Engineering, which is primarily located in 10 l 11 I Houston, and the B&R Construction and QA organizations, 12 ;
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which are located at the site.
14 15 If the Project Site Engineering organization has the 16 ;
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necessary technical resources to evaluate the requested ig!
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change, and the request is approved, the Site Engineering 30 I Project Manager issues a DCN.
If the proposed change requires gy 22 technical resources not available at the site, he forwards 23 i 24 I the proposal to the B&R Engineering Office in Houston for 25 ;
26 i evaluation.
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The design verification process, whether at the site or 29 30 '
in Houston, includes independent engineering review and 31 '
32 verification to assure that the design change is consistent i
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with the intended design criteria for the affected structure, 35 !
system, or component.
36 37 Q. 21 What is the composition of the B&R Project Site 38 i
39 Engineering Group, and how has it been enhanced?
40 41 i A.
21 The Project Site Engineering organization is 42 43 i made up of a group of qualified Engineers from each of the 44 i
45 design disciplines and the Engineering Quality organization.
I 46 47 i Qualification and training records are maintained on these 48 49 j
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3' 4j personnel.
Each Project Site Engineer is responsible to the fl Project Engineer of his discipline for the technical aspects 7 ',
of the job, is a member of that design discipline, is competent 8,
9' in the requirements and objectives of the original design, 10 ;
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and has access to pertinent background information.
12 i 13 In response to the Order the Project Site Engineering 14 13 ;
organization was expanded from 40 to 80 engineers.
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Q. 22 How does the upgrading of the Project Site T.3' 1
Engineering Staff improve the design change system?
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A. 22 In the past, the Project Site Engineering organiza-21 22 tion had limited capability to approve design changes without 23 '
24 the prior approval of the Discipline Project Engineer at 25 26,
B&R's Houston Engineering Office.
With the new design 27 1 23 j change control system, however, both the responsibilities 29 30 -
and capabilities of the Project Site Engineering organization i
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have been signi.ficantly expanded.
This has resulted in more 33 -
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timely and competent design review of the proposed changes 30 at the site.
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37 The NRC Investigation Report stated that some QC Inspectors 38 39 -
expressed uncertainty about whether Engineering was adequately 40 :
41 i informed of the conditions at the site when they were reviewing 42 i 43 ;
FREAs.
By locating more of the Engineering on field changes 44 l 45 j at the site, we have substantially enhanced the ability of 46 the Engineer to see for himself.
At the same time, we have 47 i
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l li 2e 3}1 increased the access of the QC Inspector to the Engineer.
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6i Q. 23 How well has the upgrading of the on-site Engineer-ing Staff worked?
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A. 23 The increased staff should permit Engineering to 11 l expedite the resolution of Field Change Requests.
Thus far 12 ;
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the number of FCR's dispositioned on site has been consistent 14 !
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with that experienced before the changes, however the trend 16,
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is toward increased on-site disposition.
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B&R Site Engineering, with its enhanced staff, is now 20 able to resolve at the site certain problems which previously f2 '
required considerable communication with Houston Engineering.
24 i For example, the Site Engineering staff was instrumental in 25 '
26 l coordinating all of the final design effort required to 27 i 28 i support the last phase of the construction of the main 29 l 30,
reservoir and essential cooling pond embankments.
31 1 32 l Q. 24 Describe the composition and function of the new 13 '
34 l B&R Engineering board, the Change Review Board.
35 l A. 24 The Change Review Board has been established 37 within B&R Engineering as a further means of ensuring that 38 39 i the impact of site-initiated design changes on plant design 40 41,
have been assessed.
The primary function of this Board is 42 i 43 :
to provide a mechanism to ensure that design reviews have 44 !
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been conducted by the proper engineering disciplines within 46 47 l the B&R Engineering organization.
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The Board is composed of representatives of the major 5'
6 engineering disciplines and Engineering Quality with a 7
Chairman appointed by the Engineering Project Manag*r.
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Copies of each DCN are issued to the Board members 10 11 prior to each meeting.
Each Board member assesses the 12 13 impact of the change on his area of design responsibility 14 15 and identifies additional changes required to accomodate the 16 17 Proposed change in question.
During the meeting, the Board
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{g Chairman assures that such reviews have been conducted, all 20 additional changes have been identified, and the change has 22 been found technically acceptab? -
When all of these matters 23 24 have been resolved, the Board Ch. r=an signs the DCN form, 25 26 signifying Board approval of the change.
27 23 The prerequisites for issuance of a DCN include documenta-29 30 tion of the reason for the change, justification for the 39 3{
change, engineering evaluation of the change, and an assess '
'3 34,
ment of the effect of the change on the plant design.
It is 3
not the function of the Board to perform detailed reviews of 3
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changes, but to ensure that such reviews have been completed 38 39 :
and to review the results thereof.
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i 41 Q. 25 Can you describe how this system has operated t
l 42 43 with respect to a recent DCN?
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A.
25 An example of how the Change Review Board has 46 47 carried out this function is illustrated by a recent change 48 i 49 l 90 '
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l t
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Li 2P 3l 4!
to the Technical Reference Document on " Piping Erection and 5i 5i Field Fabrication Criteria".
This proposed change was 7i 3l processed and sent to the Board by the Mechanical Discipline 9i gj to provide a more practical tolerance for fillet weld sizes 1i 2l n pipe supports.
The Board representative from the Supports 3!
Discipline determined that the Technical Reference Document, 5'
" Criteria for the Design of Pipe Supports" should also be 6.
7l revised.
Based on this determination another change was
&\\9i generated by the Supports Discipline.
0, 1:
Q. 26 How does the addition of the Change Review Board 23l improve the design change system?
4!
A. 26 The NRC Investigation Report questioned whether 5
6j the design change process adequately considered the cumulad 7i 8i tive impact of design changes.
The Change Review Board 9i 0'
proeides added assurance that each design change receives an 1l 2l adequate interdisciplinary review and that Engineering 3l adequately considers the cumulative effect of design changes.
45I Q. 27' How well has the Change Review Board system 6l 7
worked?
8 Ol 9
A. 27 The Change Review Board has worked well to date.
I 1!
The Board provides added assurance that the impact of a 2!
3l site-initiated design change will be fully evaluated by all 4!5j disciplines.
Although RL&P does not participate directly on 6
7 the Change Review Board, HL&P Engineering reviews and approves 8
9 0
i ~
Li 2;
3l 4I all DCN's written against basic design documents.
EL&P 5i g!
Engineering also reviews selected DCN's written against 7i gl detailed design documents.
9' 3l Q. 28 Describe the new design change tracking system.
2l.
1 A. 28 We are now using a computer based control system 3!
to keep track of design changes and provide "real-time" 4'
5 information on the status of design.
Each day a description 67l of each DCN processed that day is entered into the computer T',
gi by Engineering personnel at the site and in the Houston 0
office.
Each morning, a computer printout is made available g
2 to users of the design documents.
The printout, with respect 3
4 to a particular document, lists each approved DCN and its a
S, effective date.
This assures that each document user will 71 3,
have up-to-date information, including all changes, on the 9
0, relevant portion of the facility design described in that 9
,{;
document.
3l Q. 29 What are the benefits of the automated design 4i l
5l change tracking system?
r 7!
A.
29 The NRC Investigation Report found an instance 3'
l 9i where the records indicated that a design change used in 3i 1l construction was not used by the QC Inspector.
This automated 2l l
3!
system will assure that everyone is using the same design.
4 l
I It will also be used by Engineers considering design changes e \\
1 s
l
- l to verify that their review fully considers all design 7I 3l changes up to the time of their review.
3i l
3!
1
-i2-
1 2
3' 4
Q. 30 Does the present field design change system 51 6'
comply with Appendix B to 10 CFR Part 50 and applicable 7
g Regulatory Guides and industry standards?
90' A. 30 Yes.
The present field design change system f
complies in all respects with the requirements of Appendix B, 3
Criteria III and VI, and with the applicable industry stand-
.4 5
ards as set forth in ANSI.
6
.7 Q. 31 Did the July 28 response to the Show Cause Order 5
g include a number of commitments by HL&P?
O A. 31 Yes.
The response described a number of changes 2
to be made and other commitments to be fulfilled.
We have 3
4 compiled a list of each of those commitments and developed a 5
6 control system to make sure the commitments are fulfilled on 7:
8 a timely basis.
These are identified in Attachment No. 1 to 9
0' my testimony.
1~
Q. 32 Were any additional commitments made by HL&P as 3l a result of the Show Cause Order?
4 3
A. 32 Yes.
HL&P and B&R management attended a public 6
7 meeting in Bay City on August 19, 1980, to answer NRC ques-8.
9I tions about HL&P's response to the Show cause Order.
The i
0; 1l NRC had published notices of the meeting well in advance and 2
3, there was a large audience.
Members of HL&P and B&R manage-4l l
5i ment made short presentations summarizing the July 28 response 6
and then the NRC Staff asked a number of questions about the I \\
8i details of how our technical studies were progressing and 9
0-1l t
I L
2, 3'
4 how we were implementing the changes we had described in our 5
~
6 written response.
Afterward the public was invited to ask 7
g questions and NRC, B&R and EL&P representatives responded.
9' Ol Answers of HL&P and B&R to some of the questions raised 1
at the meeting included additional commitments.
These 2,
3' commitments and their current status are also described in 4
5 Attachment No. 1.
6 7
Q. 33 Has HL&P completed satisfying all of the commit-El 9;
ments made in the response to the Show Cause Order and at 0'
the public meeting?
2 A. 33 As shown in Attachment No. 1, almost all of the 3
4 236 identified commitments have been completed.
Of those 5
6 that are not complete, many are continuing commitments that 7'
8 are being and will be fulfilled over the course of the 9
0 project, such as the periodic meeting of the QAMRB.
Other 1
2; commitments require long-term efforts that are underway, 3 i such as the reexamination and any necessary repair of safety 4
5 related welding.
6!.
7!
However, the organization, personnel and staffing 8'
9' changas described in the testimony of Mr. Oprea, Mr. Frazar,
[
l 0i l
1:
Mr. Vurpillat and Dr. Broom have all been implemented.
2i l
3:
Similarly the studies of backfill, concrete and welding have I
45l been completed.
The results of that work are described in 6
the testimony of the witnesses on those technical areas.
l 8l l
9i O;
1 !
I i
l
L, 2.
3l 4,
Q. 34 Please describe the control system that HL&P has 5
6 adopted to track compliance with each commitment made by 7
g; HL&P.
9 A. 34 The system which we established consisted of g
1 several levels of review.
The initial version of the document 2*
3 attached to this testimony. as Attachment No. 1 was sent to 4
5 the NRC on September 18, 1980 as a baseline document for 6
74 comparison purpose.
Updates of the Commitment List have 5
g, been distributed to HL&P and B&R Executive Management, and 0
other personnel involved in our effort.
As I discussed
_9,f previously, this document showed the reference of the commitment 3
4 source, for example, the public meeting or the written Show 5
6 Cause response.
It also shows the in-house due date for 7
8 completion and the status.
The List was revised in March to 9
0 indicate the status of the NRC review.
So this List is part 9
~
of the system.
3>
The next integral part was a weekly update of the 4
c i status of the items.
B&R supplied HL&P with a weekly update 6
7 which was then distributed.
I used these documents to 8
9 monitor the progress of B&R and EL&P on these commitments.
0:
i 1
The backup to these lists was a set of files kept by I
2 3:
our site QA personnel.
For each Show Cause Order commitment 4:
5I ur site QA personnel would either get a copy of the document 6'
l that closed out the commitment and put it in the file or l
8-9, 0l 1i l :
I
L L
3<
1 placed a reference page in the file.
In either case EL&P 5
i!
personnel reviewed the documents to satisfy ourselves that i
3, the commitment was being implemented.
)
Q. 35 Does this system assure that each commitment
)
L will be fulfilled on a timely basis?
2, 3'
A. 35 Yes.
The system established a working list with 4
5 assigned responsibilities and due dates.
It provided a 5
7 helpful mechanism for my use in determining the management 5
g efforts required to make sure the commitments were met on 0
time.
That it has worked is shown by the status of the 9-n commitments.
Action has been taken on all of the commitments 3'
4 and NRC has inspected using our commitment list as a checklist 5
6 and has closed out most of the commitments.
7 3
i 9
0 9
~
T. Hudson:09:B i
3, 4
5' 6
7 8'
9 0
1l 2
3:
4; 5l 6
7' 8 i 9
0 1
i
-is-
Att chtent No. 1 SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page H-1 ITEM COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS NO.
H1 Mr. Oprea and Mr. Grote on Due Date 10/5/80 Reso:
R. A. Frazar distribution for a number of QA W. J. Friedrich Reports. Ref:
Page 54 STP Status:
Complete - GWO receives Audit, Trend and Monthly Activity Reports.
SHG receives Audit and Trend Reports, Stop Work Orders and Status of CAR's.
NRC Status:
Closed per 81-01 H2 Mr. Grote will spend 90% of his time Due Date N/A Reso:
S. H. Grote on STP, and he will vi>it the Site on STP Status:
Continuous commitment - item a regular basis, closed Ref: Page 51, 54, & 55 NRC Status: Closed oer 81-04 H3 QAMRB Meetings to be held on Site.
Due Date N/A Reso:
R. J. Yuroillat, Jr.
Ref: Page 56 STP Status.
Continuous commitment - item closed NRC Status: Closed per 80-27 H4 B&R Corocrate QA Manager to mke a Oue Date N/A Reso:
R. J. Vurpillat, Jr.
report once a month to the operating STP Status:
Continuous comitment - item committee'and board of 3&R concerning closed the status, of tne STP QA Program.
NRC Status: Closed per 81-01 Ref:
Page'56 l
H5 Establisn system to track each Show Oue Date 9/19/80 Reso:
J. W. Briskin l
Cause Commitment and supply to NRC a STP Status:
Complete - See ST-HL-AE-533 timetable so tney can schedule their 9/18/80.
inspection consistent with schedule NRC Status: Closed cer 80-27 for work development.
Ref: Page 58 - 59 H6 Provide update of FSAR Chapter 17 Due Date 11/1/80 Reso:
R. A. Frazar describing new organization and in STP Status:
Comolete - See ST-HL-AE-568 addition a comparison to previous NRC Status:
Closed per 80-27 organization including reporting system, number and type of classification of people.
Ref: Page 60 & 67 H7 Coordinators from Construction and QA Due Date _9/_15/80 Reso:
R. H. Leasburg assigned for complex concrete pours.
W. J. Friedricn Ref: Page 63 STP Status: Comolete - See SQA 4280 NRC Status: Closed per 80-38
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page H-2 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS H8 AWS Welding Procedures have been Due Date N/A Reso:
R. H. Leasburg revised, ready to requalify welders, W. J. Friedrich and have completed mucn of the STP Status: Continuous commitment - item personnel training.
closed Ref: Page 64 NRC Status: Closed per 80-38 H9 At tne restart of AWS welding, work Due Date N/A Reso:
W. J. Friedrich will be overseen by certified Level STP Status: Coitinuous commitment - item III Examiner.
closed Ref: Page 65 NRC Status: Closed per 80-38 d10 Provide to NRC a senedule of Due Date 9/12/80 Reso:
M. D. Muscente outstanding commitments concerning STP Status: Complete see ST-HL-AE-545 and welding.
ST-HL-AE-532.
Ref: Page 66 - 67 NRC Status: Closed per 80-38 H11 Provide to the NRC a grapnical Due Date 11/1/80 Resp:
R. A. Frazar presentation of tne kind of pecole and W. J. Friedricn qualifications that existed prior to STP Status: Comolete - See ST-HL-AE-568 the cnange and nen wnat changes are NRC Status: Closed per 81-01 being made so NRC can nave a better understanding of what has been done and better track how things are going in future.
Ref:
Page 67 - 68 i
Due Date 9/26/80 Reso:
G. W. Oorea, Jr.
H12 Provide to NRC the results of analysis of Becntel/MAC recommendations.
STP Status: Comolete See ST-HL-AE-548, Ref: Page 74 9/24/80.
I NRC Status: Closed per 80-27 1
dl3 All construction procedures revised in Due Date 11/28/80 Reso:
R. H. Leasburg new format with input from Crafts /QA K. R. Cook by end of November.
STP Status: Complete - See GM 76688 l
Ref: Page 77 NRC Status:
Partial closure of civil item per l
80-38 i
1 1
l
l SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page H-3 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS H14 Schedules will be established whereby Due Date N/A Resp:
R. H. Leasburg in a timely manner QC Inspectors /
W. J. Friedrich Craftsmen will receive adequate STP Status: Complete - This is a requirement training on revised procedures, (prior in Procedure GCP-1 prior to to procedure implementation).
implementation of each revised Ref:
Page 78 & 80 procedure. This is also a requirement of the Quality Assurance Plan Section 6.1.
NRC Status: Closed per 81-04 H15 Provide NRC the HL&P Quality Assurance Due Date 9/15/80 Resp:
R. A. Frazar and Quality Control Organizations STP Status: Complete See ST-HL-AE-541, staffing levels, how we arrived at 9/24/80 tnem, what was the criteria for NRC Status: Closed per 81-04 arriving at those numbers.
Ref: Page 95 - 96 H16 Provide NRC with decision on frequency Due Date 2/81 Resp:
G. W. Oprea, Jr.
of audit by outside consultant.
STP Status: Complete Ref:
Page 104 NRC Status: Closed per 80-27 H17 Check qualifications of construction Due Date 1/16/81 Resp:
J. R. Geurts personnel now working on Site.
STP Status: Complete (Construction Supervisory Personnel)
NRC Status: Civil part closed per 81-03 Ref: Page 109 - 113 Remainder open H18 Provide to NRC the recommendations of Due Date 9/15/80 Reso:
R. H. Leasburg dynapac cw'7 action equipment.
STP Status: Complete - See ST-HL-AE-530 Ref:
Page 115 NRC Status: Closed per 80-38 l
l H19 Provide additional information to Show Oue Date 11/10/80 Reso:
J. L. Hawks Cause Item 2.8, addressing the C. B. Pettersson question of foundation settlement.
STP Status: Complete - See GM-75521 Ref:
Page 118 NRC Status: Closed per 80-38 1
H2O Provide NRC with copy of PDCN to Due Date 10/1/80 Reso:
J. L. Hawks backfill TRD (Rev. B) and issue DCN C. B. Pettersson within 4-6 weeks.
STP Status: Complete - Ref:
3A700GP002-A l
Ref:
Page 125 DCN 9/24/80 l
NRC Status: Closed per 80-38 l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page H-4 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS
'E H21 Final report to be available Due Date 11/30/80 Resp:
J. L. Hawks mid-October regarding the work of the C. B. Pettersson Independent Review Cormlittee in the STP Status: Complete - See ST-BR-HL-36189 soils area.
ST-SH-BR-28 Ref:
Page 126 ST-HL-AE-625 NRC Status: Closed per 81-03 H22 Complete mapping of the backfill Due Date 10/15/80 Resp:
J. L. Hawks construction activities by C. B. Pettersson mid-September and issue final report STP Status: Complete - See ST-BR-HL-36189 by mid-October.
ST-SH-BR-28 Ref:
Page 127 ST-HL-AE-625 NRC Status: Closed per 81-03 H23 Modified the documentation systems for Due'Date N/A Resp:
W. J. Friedrich AWS welding such that verification can STP Status: Complete be made of inspectors performing in NRC Status: Closed per 80-38 process checks on AWS welding.
Ref:
Page 143 H24 Socket welds to be 100% reinspected.
Due Date 11/14/80 Ress:
M. D. Muscente Ref: Page 145 W. J. Friedrich SD Status: Complete - item was delayed unti' 11/24/80 because ASME - restart was delayed.
See ST-HL-AE-532 and 545 NRC Status: Closed per 81-06 H25 Manager of welding to issue monthly a Oue Date 10/1/80 Reso:
M. D. Muscente written report regaroing status of STP Status: Complete - See BC-30663 welding, problems being incurred, and NRC Status: Closed per 80-38 actions being taken.
Ref:
Page 156 H26 Provide a copy of welding task force Due Date 9/12/80 Resp:
M. D. Muscente report to HL&P for transmittal to NRC.
STP Status: Complete. See ST-HL-AE-545 and Ref: Page 156 ST-HL-AE-532.
NRC Statu:: Closed per 80-38 H27 Obtain copy of Public Law 96-295.
Due Date 10/1/80 Resp:
R. A. Frazar Evaluate for possiole incorporation STP Status: Complete - Law is to be posted.
into appropriate documents.
NRC Status: Closed per 80-27
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page H-5 ITEM COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS NO.
H28 Review NCR Procedure to see if Due Date 9/15/80 Reso:
W. J. Friedrich clarification is needed in cases where STP Status: Complete - Ref. St-QAP-15.1 inspectors cannot obtain NRC Status: Closed per 80-27 acknowledgement of NCR from construction.
Ref: Page 165 H29 Each month the Project QA Manager is Due Date 10/80 Reso:
W. J. Friedrich to present to QAMRS a status of each STP Status: Continuous commitment - item outstanding ADR, (i.e. how long its closed been open and how long it is overdue).
NRC Status: Closed per 80-27, 81-01 In addition NCR's & CAR's substantially past their due date will be presented.
Ref: Page 174 - 175 H30 All design changas will be documented Due Date 10/1/80 Resp:
J. L. Hawks on a Design Change Notice (DCN).
STP Status: Complete - Ref. STP-0C-028 Ref: Page 177 Effective 10/1/80 NRC Status: Closed per 81-05 H31 All B&R/HL&P Audit Reports, including Due Date 9/8/80 Resp:
R. L. Ulrey Vendor Audits Reports are being sent R. W. Bass to G. W. Oprea, W. M. Rice and S. H.
STP Status: Complete.
Grote for review.
HL&P: Audit Reports will continue to be sent Ref:
Page 182 to Executive Management.
B&R:
Distribution List for B&R has been revised to include these personnel for all future audit reports.
NRC Status: Closed per 81-04 l
l l
l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page M-1 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY ST ATUS M1 PQAS will assess the Quality Due Date 10/1/80 Reso:
R. A. Frazar Engineering and inspection functions STP Status: C:colete, see PSQP-A9 Rev. O of B&R by performing mini-audits, NRC Status: 0 en/ Ready for NRC Review reviews and approval of procedures and observation of work activities in the field.
Ref. Para:
1 - 11 (1)
M2 Review has been made of the Due Date 8/4/80 Reso:
G. W. Oorea, Jr.
qualifications of all key QA personnel STP Status: Comolete.
witnin HL&P/8&R by Bechtel and MAC.
NRC Status: Closed per 81-04 Ref. Para:
1 - 16 (4)
M3 Trending various types of deficienciet Due Date 1/31/81 Reso:
W. J. Friedrich
~
will reflect any significant failures J. Purdy to comply with procedural STP Status: Comolete - Part of the Trending requirements, and provide management Program with information on wnich to base NRC Status: Closed per 80-27 continued imorovements in training.
Ref. Para:
1 - 18 (1)
M4 B&R audit group to add five additional Due Date 1/1/81 Reso:
R. W. Sass personnel to augment Audit Staff STP Status:
Site is authorized a total 7 (NUS/SAI).
auditors, Houston Office 15 Ref. Para:
1 - 19 (2) auditors.
NRC Status: Closed per 80-27 MS A requirement has been established for Due Date N/A Reso:
W. J. Friedrien periodic meetings at tne Site which STP Status:
Initiated and is an on-going will be attended by key upper and activity. Montnly meetings nave middle management personnel of been held since July 1980 witn i
HL&P/B&R.
Each meeting will include a B&R QAMRS and G. W. Oorea and l
report on the status of the QA program Staff in attendance.
nignlignting Quality problems, trends, NRC Status: Closed oer 81-01 etc.
Ref. Para:
1 - 20 (2) l G6 With Senior Officers of B&R acting as Due Date N/A Reso:
K. M. Broc, l
an Oversign: Committee and Line STP Status:
Item comolete.
Mr. C. Snycer Managers comorising a Steering neads the Steering Committee.
i Committee tne Corporate Committee to Messrs Rice, Grote, Bazor, Quality imorovements will be expressed Salterillo, and Dr. Broom l
throJgn training and indoctrination comorise the Oversignt Committee l
and innovative programs.
These functions shall be ongoing Ref. Para:
1 - 20 (3) for the life of tne project.
I NRC Status: Closed per 81-01 l
SHOW CAUSE COM VilTMENTS EDITION 04-08-81 Page M-2 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS M7 The Independent Review Committee has Due Date 12/15/80 Resp:
J. L. Hawks evaluated the field and laboratory C. B. Pettersson data and nas presented conclusions in STP Status: Complete - See ST-HL-AE-625 interim report. Final evaluation will ST-SH-BR-28 be presented in a comprehensive report ST-BR-HL-36189 upon conclusion of all planned studies NRC Status: Closed per 81-03 related to Cat. 1 Structural Backfill.
Ref. Para:
2 - 11 (2)
M8 A comprenensive engineering study is Due Date 12/15/80 Reso:
J. L. Hawks being made of construction conditions, C. R. Pettersson placement seaueace &t testing of Cat.
STP Status: Complete - See ST-HL-AE-625 1 StructJral Backfill placed at STP.
ST-SH-BR-28 Ref. Para: 2 - 17 (2)
ST-BR-HL-36189 NRC Status: Open/ Ready for NRC review M9 Locations and sequence of various Cat.
Due Date 12/15/80 Resp:
J. L. Hawks 1 backfill placements and C. B. Pettersson correspondence in-place density test STP Status: Complete - See ST-HL-AE-625 results will be documented for units 1 ST-SH-BR-28
& 2 together with summaries of the ST-BR-HL-36189 report construction methods and NRC Status: Open/ Ready for NRC review conditions. Specifically placements in support of the foundations for F.H.B., M.E.A.B., and 0.G.B. as well as backfill surrounding these buildings and against R.C.B.
The bedding and backfill for tne essential cooling water system piping are also to be included.
Ref. Para:
2 - 18 (3)
M10 An evaluation will be made of the Due Date 12/15/80 Reso:
J. L. Hawks l
validity and representativeness of the C. B. Pettertson inplace density test data based on the STP Status: Complete - See ST-HL-AE-625 inspection reports, considering the ST-SH-BR-28 reported construction methods, ST-BR-HL-36189 sequence, and conditions.
NRC Stats.. Open/ Ready for NRC review Ref. Para: 2 - 19 (2)
SHOW CAUSE COMMITVIENTS EDITION 04-08-81 Page M-3 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS M11 Statistical analyses will be performed Due Date 12/15/80 Reso:
J. L. Hawks using in-place density test results.
C. B. Pettersson Ref. Para: 2 - 19 (3)
STP Status: Complete - See ST-HL-AE-625 ST-SH-BR-29 ST-BR-HL-36189 NRC Status: Open/ Ready for NRC review M12 A comorenensive evaluation !s being Due Date 12/15/80 Resp:
J. L. Hawks performed of FSAR Section 2.5.4 C. B. Pettersson Ref. Para: 2 - 33 (1)
STP Status: Complete NRC Status: Closed per 81-03 M13 dased on the evaluation completed to Due Date 12/15/80 Reso:
J. L. Hawks date an FSAR Amendment will be C. B. Pettersson submitted to clarify the description STP Status:
Submittal to licensing by of the construction process.
3/10/81.
Ref. Para: 2 - 33 (1)
NRC Status: Open/ Ready for NRC review M14 A complete review of Earthwork Due Date 12/15/80 Reso:
J. L. Hawks Inspection Reports is being performed STP Status: Complete - See ST-BR-HL-36189 to furtner verify compliance with the ST-SH-BR-28 construction and inspection ST-HL-AE-625 requirements.
NRC Status: Closed per 81-03 Ref. Para: 2 - 35 (3)
M15 FSAR Subsection 2.5.4.5.6.2.4 will be Due Date 9/15/80 Reso:
A. H. Geisler revised.
STP Status: Comolete - Amend.12 to FSAR Ref. Para: 2 - 36 (2)
ST.HL-AE-527.
NRC Status: Open/ Ready for NRC review M16 FSAR Suosection 2.5.4.5.6.2.5 will be Due Date 9/15/80 Reso:
A. H. Geisler revised.
STP Status: Complete - Amend. 12 to FSAR Ref. Para:
2 - 36 (2)
ST-HL-AE-527.
NRC Status: Open/ Ready for NRC review M17 A comprenensive or'ogram to re-assess Due Date 7/7/80 Reso:
J. L. Hawks and verify safety related welding at T. J. Natarjan STP, and to determine wnether tne STP Status: Complete. See DCN 7/3/80 to TRD safety related work conoleted was 5A700GP004 oroperly performed.
NRC Status: Closed per 80-38
SHOW CAUSE COMMITIV EN S
EDITION 04-08-81 Page M-4 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS M18 The task force (safety-related Due Date 9/12/80 Resp:
D. Muscente welding) will establish a schedule for STP Status: Complete. See ST-HL-AE-545 and any repair work as a result of ST-HL-AE-532 discrepancies identified during NRC Status: Closed per 80-38 review.
Ref. Para: 3a - 1 (2)
M19 The Task Force (safety-related Due Date N/A Reso:
J. L. Hawks concrete structures) will establish G. R. Murphy schedule on any repair work.
STP Status:
No repair work identified to Ref. Para: 3b - 2'(1) date.
NRC Status: Closed per 81-03 M20 RCB's (Unit 1 & 2) Review to be Due Date 9/15/80 Resp:
J. L. Hawks completed by September 15, 1980 as G. R. Murphy revised by letter ST-HL-AE-521.
STP Status: Complete - See ST-BR-HL-36470 Ref. Para: 3b - 2 (2)
NRC Status: Closed per 81-03 M21 MEAS (Unit 1 & 2) Review to be Due Date 10/15/80 Resp:
J. L. Hawks completed by October 15, 1980 as G. R. Murphy revised by letter ST-HL-AE-521.
STP Status: Complete - See ST-BR-HL-36470 Ref. Para:
3b - 2 (2)
NRC Status: Closed per 81-03 M22 FHS (Unit 1 & 2) Review to be Due Date 10/31/80 Reso:
J. L. Hawks completed by November 15, 1980 as G. R. Murphy revised by letter ST-HL-AE-521.
STP Status: Complete - See ST-BR-HL-36470 Ref. Para: 3b - 2 (2)
NRC Status: Closed per 81-03 M23 Sampling by coring, chipoing and Due Date 8/15/80 Reso:
J. L. Hawks boring in Unit 1 RCB will be G. R. Murphy accomplished in next two weeks.
STP Status: Complete. Ref:
ST-HL-AE 513 (August 12,1980)
NRC Status: Closed per 80-38 Ref. Para:
3b - 4 (3), 3b - 5 (1)
M24 A status report by the Task Force will Due Date 8/15/80 Reso:
J. L. Hawks be submitted to NRC I&E Region IV by G. R. Murony August 15, 1980.
STP Status: Complete.
Ref:
ST-HL-AE-513 Ref. Para:
3b - 5 (1)
NRC Status: Closed per 80-38
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page M-5 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS M25 Documentation review for Unit #2 RCB Due Date 8/1/80 Resp:
J. L. Hawks is scheduled to be finished in the G. R. Murphy next montn.
STP Status: Complete.
Evidence o' review Ref. Para:
3b - 8 (2) documented on Document Review Checklist.
NRC Status: Closed per 81-03 M26 Testing on Unit 1 RCB is expected to Due Date 8/15/80 Reso:
J. L. Hawks be complete by August 12, 1980.
G. R. Murphy Ref. Para:
3b - 12 (2)
STP Status: Complete. Ref:
ST-HL-AE-513 NRC Status: Closed per 80-38 M27 Brochure is being replaced with a new Due Date 8/1/80 Resp:
K. M. Broom QA program brochure-approved by HL&P STP Status:
Complete.
Text of the new tnat reflects the fundamental brochure was provided with philosophy of 10CFR50 Part 50 App.
response to Show Cause Order.
"B".
NRC Status: Closed per 80-27 Ref. Para: 4 - 1 (2)
M28 New seminars for construction and Q.C.
Due Date N/A Reso:
K. M. Broom personnel on objectives and standards STP Status: Started and on-going.
of HL&P/B&R QA Programs as they relate NRC Status: Closed to STP will be commenced promptly.
Ref. Para:
4 - 1 (2), 4 - 2 (1)
M29 Procedures defining stop work Due Date 8/15/80 Reso:
R. A. Frazar authority (HL&P & B&R) will be issued W. J. Friedrich for use by August 15, 1980.
STP Status: HL&P Ref. Para:
5 - 5 (3)
Procedure PSQP-A7 issued definin t
"Stop Work" authority, i
STP Status: B&R l
Procedure QAP-15.2 issued 8/15/80.
NRC Status: Closed per 80-27, 80-38 l
M30 Necessary procedures describing the Due Date 9/30/80 Reso:
W. J. Friedrich Inspection Report System and Material STP Status: Complete - see ST-QPA-15.1 and Review Board will be issued in 15.5 issued 10/15/80.
September, 1980.
NRC Status: Closed per 80-27, 81-04 Ref. Para:
6 - 8 (3)
M31 Attempt to expedite ANI Review of Q.A.
Due Date N/A Reso:
J. R. Geurts Manual will be made.
STP Status:
Will be started when QAM is Ref. Para:
6 - 8 (3) revi sed.
NRC Status: Open/ Ready for NRC Review
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page M-6 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS M32 Detail procedures for DAG will be Due Date 8/15/80 Resp:
W. J. Friedrich finalized in mid-August, 1980.
STP Status: Complete. QAP 15.4, " Trend Ref. Para: 6 - 11 (1)
Analysis", was issued on 8/15/80.
NRC Status: Closed per 81-04 M33 Personnel training in DAG procedures Due Date 8/29/80 Reso:
W. J. Friedricn will be conducted and procedures STP Status: Complete.
Training was held on implemented in early September, 1980.
8/29/80, however training is an Ref. Para: 6 - 11 (1) ongoing activity for the life of the project.
NRC Status: Open/ Ready for NRC Review M34 OAG First Quarterly Report is expected Due Date 1/31/81 Resp:
W. J. Friedrich to be issued for fourth quarter 1980.
STP Status: Comolete Ref. Para:
6 - 11 (1)
NRC Status: Open/ Ready for NRC Review M35 A Change Review Board will be Due Date 10/1/80 Resp:
J. L. Hawks established witnin B&R Engineering, STP Status: Complete - see STP-DC-029 botn at the Site and Houston Office.
effective 1Q/1/80.
Ref. Para:
7 - 4 (2)
NRC Status: Closed per 80-36 M36 The Engineering Project Manager will Due Date 10/1/80 Reso:
J. L. Hawks appoint a chairman at each location.
STP Status: Complete - see ST-0C-029 Ref. Para:
7 - 4 (2), 7 - 5 (1) effective 10/1/80.
NRC Status: Closed per 80-36 l
l M37 All procedures for control of field Due Date 10/1/80 Reso:
R. W. Peverley changes will be issued by August 29, STP Status: Complete - see ST-CC-028, 029, l
1980. Revised to October 1, 1980.
and 023 effective 10/1/80 Reference ST-AE-520.
NRC Status: Open/ Ready for NRC Review Ref. Para:
7 - 8 (3) l M38 Training seminar is being prepared and Due Date 10/1/80 Reso:
R. W. Peverley will be presented to all B&R members STP Status: Complete - see GM-70976.
who participate in this program.
fiRC Status: Open/ Ready for NRC Review Ref. Para:
7 - 8'(4) l M39 Instructions for implementation Q.A.
Due Date 8/1/80 Resp:
W. J. Friedrich l
Records will be issued by August 1, STP Status: Complete.
l 1980.
NRC Status: Closed per 80-36 Ref. Para:
8 - 4 (3) l
SHOW CAUSE COMMFM ENTS 841 EDITION 04-08-81 Page M-7 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS FUS Completed generic checklist for all Oue Date 11/1/80 Reso:
W. J. Friedrich safety-related records will be in use STP Status: Complete - see QAI-17.1-1 and ch by Novemoer 1, 1980.
Aopendix; ST-QAP-17.1-4.
Ref. Para: 8 - 4 (3)
NRC Status: Closed per 80-36 On-site microfilming capability will Oue Date 01/31/81 Reso:
W. J. Friedrich b2 in place and staffing and training STP Status: Comolete cocolete by January 31, 1981.
NRC Status: Closed per 81-05 1 sed Ref. Para: 8 - 4 (3)
B&R will increase the numoer of Due Date 1/81 Reso:
R. W. Bass Resident Site Auditors.
STP Status: Cocolete - See Commitment No.
Ref. Para:
9 - 3 (4), 9 - 4 (1)
M-4.
NRC Status: Closed per 80-27 i
l 1
l l
icn on I
er1ng j
zation
I SHOW CAUSE COMMITMENTS EDITI(.N 04-08-81 Page A-2 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS A8 B&R Q.A.E. are responsible for Due Date01/15/81 Resp:
W. J. Friedrich performarice of: a) Document Reviews STP Status:
In process - full b) P. O. Reviews; c) Nanconformances; implementation upon complete and d) preparation of Inspection staffing.
Checklist.
NRC Status: Open/ Ready for NRC Ref. Para:
1 - 14 (3)
A9 Inspectors are advised of the Due Date 10/15/80 Resp:
W. J. Friedrich Disposition of Findings (NCR's)
STP Status: Complete. See ST-QA215.1 Ref. Para:
1 - 15 (2)
NRC Status: Closed per 80-27 A10 Upper level management of HL&P will Oue Date N/A Reso:
G. W. Oprea, Jr.
also participate directly in all K. M. Broom aspects of the project, including QA STP Status: On-going - all upper functions. Frequent on-site visits management have committed to and meetings to review progress and frequent periods of time.
proolems will be conducted.
Many meetings with QA Ref. Para:
1 - 16 (2)
Construction and Engineering have occurred since June 1980.
NRC Status: Closed per 81-01 All HL&P Executive V. P. will also Due Date N/A Reso:
G. W. Oprea, Jr.
participate in periodic meeting of the STP Status: On-going - Mr. Oprea has B&R Q.A. Management Review Board, attended the monthly QAMRS Ref. Para:
1 - 16 (3) meetings at the Job Site since July 1980.
NRC Status: Closed per 80-27 A12 Review has been made of the Due Date 8/4/80 Resp:
G. W. Oprea, Jr.
qualifications of all key QA personnel STP Status: Complete l
within HL&P/B&R by Bechtel and MAC.
NRC Status: Closed 81-04 l
Ref. Para:
1 - 16 (4) i 1
A13 B&R will continue to upgrade Due Date N/A Reso:
K. M. Broom qualifications of its QA/QC Management STP Status: Started and on-going.
Team.
Upgrading to be accomplished by NRC Status: Closed per 81-04, 01 formal and informa1 training l
activities and counseling of i n d'. vi dua l s.
Ref. Para:
1 - 17 (2) l l
t
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-3 ITEM COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS NO.
A14 Technical Training Programs for QA/QC Due Date 9/15/80 Resp: Vurpillat personnel to ensure full knowledge of STP Status: Completed - ST-QAP-2.2, and procedural requirements have been and GCP-1 to be used on continuous will continue to be conducted, basis.
Ref. Para:
1 - 17 (3)
NRC Status: Closed per 81-04 l
A15 Program of retraining Inspectors and Due Date 1/1/81*
Reso:
R. H. Leasburg Crafts is currently underway.
W. J. Friedrich Ref. Para:
1 - 19 (3)
STP Status: Required by GCP-1 and ST-QAP-6.1; encompasses all procedures developed and revisions to procedures.
- For Crafts NRC Status: Closed per 81-04 A16 Quality Engineers are establishing the Due Date 1/1/81 Reso:
W. J. Friedrich necessary training programs to update STP Status: See A15 above.
construction and QC personnel on newly NRC Status: Closed per 81-04 established Quality requirements.
Ref. Para:
1 - 19 (3)
I l
A17 In area of revised procedures, Due Date 1/1/81 Reso:
R. H. Leasburg indoctrination and training sessions W. J. Friedrich are underway to educate personnel on STP Status: See A15 above.
cnanges in QA procedures, organization NRC Status: Closed per 81 04 interfaces and responsibilities.
Ref. Para:
1 - 19 (3)
A18 A requirement has been established for Due Date N/A Resp:
D. G. Barker periodic meetings at the site which J. R. Geurts will be attended by key upper and STP Status: Started and on-going.
middle management personnel of NRC Status: Closed per 81-01 HL&P/B&R.
Each meeting will include a i
j report on the status of the QA program nignlignting Quality problems, trends, etc.
i Ref. Para:
1 - 20 (2) l l
l A19 The QA programs of HL&P are being Due Date 10/1/80 Resp:
R. A. Frazar
(
revised to include an annual audit by STP Status: Comolete. See PSQP A-1 an independent consultant.
NRC Status: Closed per 80-27 Ref. Para:
1 - 21 (1) l 1
l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 1
Page A-4 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS 3
B&R/HL&P Cat. I structural backfill Oue Date12/15/80* Resp:
J. L. Hawks task force identified the following C. B. Pettersson reviews to be performed.
STP Status: Complete - See ST-HL-AE-625 ST-BR-HL-36189 a) Reconfirm the adequacy of the ST-SH-BR-28 construction methods used during NRC Status: a) Closed per 80-24 Cat. I structural backfill b) Closed per 80-24 placements.
c) Open d) Open b) Comparison of backfill material e) Open tested for the engineering design f) Open studies with material actually g) Open placed.
h) Open i) Closed per 80-24 c) Plan views and profiles to show the sequence of backfill placements and lift thickness.
d) Review of all earthwork inspection reports.
a) Statistical analysis of the in place density test to determine the postulated density distribution.
f) Determination of the relative density requirements of the backfill.
t g) Analysis of the significance of l
density distribution within the l
surface lift, immediately below Cat. I structural foundations.
- 1) Review of previous boring program results for evaluation of the l
engineering adequacy of the bockfill.
- 1) Comparative determinati,on of max / min laboratory density test results by an independent laboratories.
j) Evaluation of all data concerning generic or specific problem with construction & quality control programs.
tef. Para:
2 - 3 (2)
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-7 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A27 The results will be used for Due Date 12/15/80 Resp:
J. L. Hawks statistical analysis of the density C. B. Pettersson distribution within the backfill, for STP Status: Complete - See ST-WC-BR-5791 evaluation of backfill placement and NRC Status: Open/ Ready for NRC compaction operations, and for assessment of the engineering adequacy of the in place backfill.
Ref. Para:
2 - 17 (2)
A28 Tne data compiled during the Due Date 12/15/80 Resp:
J. L. Hawks evaluation will also be used as input C. B. Pettersson to the studies of the adequacy of the STP Status: Complete existing backfill.
NRC Status: Open/ Ready for NRC Ref. Para: 2 - 17 (2), 2 - 18 (1)
A29 The data compilation is described in Due Date 12/15/80 Reso:
J. L. Hawks B&R TRD 3A700GP001-B.
C. B. Pettersson Ref. Para: 2 - 18 (2)
STP Status: Complete NRC Status: Open/ Ready for NRC A30 Earthwork Inspection Reports will be Due Date 12/15/80 Reso:
J. L. Hawks carefully reviewed to determine C. B. Pettersson whether or not the reported activities STP Status: Complete are in accordance with applicable NRC Status:
Open/ Ready for NRC specification and construction procedures.
Ref. Para: 2 - 19 (1) l A31 Ine in place density test data and Due Date 12/15/80 Reso:
J. L. Hawks statistical results will also be C. B. Pettersson evaluated in comparison to the results STP Status: Complete - See ST-WC-BR-5797 of tne soil test boring program.
NRC Status:
Open/ Ready for NRC Ref. Para: 2 - 19 (4) i A32 Tne independent review committee has Due Date 12/15/80 Resp:
J. L. Hawks reviewed all pertinent aspects of the C. B. Pettersson structural backfill design studies, STP Status:
Complete - See ST-HL-AE-625 specification criteria, construction ST-SH-BR-28 l
l procedures and inspection and testing NRC Status: Closed per 81-03 documentation.
Ref. Para: 2 - 28 (2)
I l
l l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-8 j
COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A33 Future inspection activities will be Due Date 6/20/80 Resp:
J. L. Hawks conducted under engineering direction C. B. Pettersson to assure satisfactory inspections STP Status: Complete.
supported by comprehensive Ref:
TRO 3A700GP005 documentation.
NRC Status: Closed per 80-38 Ref. Para:
2 - 36 (1)
A34 Safety-related welds being examined by Due Date 12/31/80 Reso:
J. L. Hawks the Task Force includes all ASME T. J. Natarajan Section III Pipe & Pipe Hanger Welds &
STP Status: Complete Seismic Cat. 1 Structural Steel Welds NRC Status: Closed per 80-38 made per AWS D1.1.
Ref. Para: 3a - 3 (3)
A35 This program defined a series of Due Date 12/21/M Reso:
J. L. Hawks activities starting with a cocolete T. J. Natarjan review of all welding documentation, STP Status: Complete review of all welder & inspector NRC Status: Closed per 80-38 qualification records; examination of the traceability of all base metal &
weld filler F:! rial; and finally l
verification siid reexamination of l
selected welds through a random sampling progru.
Ref. Para; 3a - 3 (3), 3a - 4 (1) l A36 The Weld Review Program has been Due Date 12/31/80 Resp:
J. L. Hawks documented in TRD 5A700GP004. The TRD T. J. Natarjan will be updated periodically to STP Status: Complete incorporate changes in the results of NRC Status: Open tne program.
Ref. Para:
3a - 5 (3)
A37 The qualifications of personnel who Due Date 10/18/80 Reso:
J. L. Hawks inspected ASME Piping & Cat. 1 T. J. Natarjan Structural Wald are being reviewed to STP Status: Complete - Nutech Letter verify that they were properly DTU-80-006/
qualified and cert'ified in accordance BR0-01-006 dated with Code & Project Requirements.
10/14/80 Ref. Para:
3a - 6 (1)
NRC Status: Closed per 80-38 l
1 l
l l
SHOW CAUSE COM VilTMENTS EDITION 04-08-81 Page A-9 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A38 For ASME Piping, the existing Due Date 12/31/80 Resp:
J. L. Hawks radiograpns and NDE Inspection results T. J. Natarjan on weld data cards, weld data repair STP Status: Complete cards, and QC Inspection Repocts are NRC Status: Closed per 81-06 being reviewed for completeness and compliance to code and project requirements.
Ref. Para:
3a - 6 (1)
A39 A review of NDE Procedures has Due Date 9/30/80 Reso:
W. J. Friedricn identified the need for improvements STP Status: Complete.
which have been and are being NRC Status: Closed per 80-38 incorporated into the NDE Procedures.
Ref. Para: 3a - 6 (2)
A40 Personnel qualifications will be Due Date 10/18/80 Reso:
W. J. Friedricn reviewed by the Brown & Root Level III STP Status: Complete - corrective action
& Task Force Level III to determine is to re-radiograph all the corrective action for tne Task accessible safety related Force findings.
Rc' Para:
3a - 7 (1)
NRC Status: Closed per 80-38 A41 Furtner review is required of previous Due Date 9/22/80 Resp:
W. J. Friedrich QA procedures and training manuals STP Status: Complete containing requirements for personnel NRC Status: Closed per 81-03 qualifications.
Ref. Para:
3a - 7 (1)
A42 In addition the Level III Program of Due Date 9/22/80 Resp:
W. J. Friedrich Certifications and NOE Examinations is STP Status: Complete being reviewed.
NRC Status: Closed per 81-03 Ref. Para:
3a - 7 (1) l A43 A reevaluation of all final acceoted Due Date 9/29/80 Reso:
W. J. Friedricn radiograpns has been performed.
STP Status:
Ine reevaluation has been Ref. Para:
3a - 7 (3) completed. The results will be issued in the final report from Southwest Researcn.
NRC Status: Closed per 80-38 A44 All AWS Cat. 1 erection documentation Due Date N/A Resp:
J. L. Hawks has been reviewed and tabulated.
D. Muscente Ref. Para 3a - 9 (2)
STP Status: All AWS accessible welds will be reexamined.
NRC Status: Closed per 80-38
SHOW CAUSE COMMITIV ENTS EDITION 04-08-81 Page A-10 COMMITMENT REF. P ARA.
DUE DATE RESPONSIBILITY STATUS A45 For AWS Cat. 1 shop welding, all shop Due Date 8/18/80 Reso:
J. L. Hawks work request have been reviewed to D. Muscente identify those request which required STP Status: Complete.
welding.
Ref:
DCN 8/15/80 to TRD SA700GP004-8.
Ref. Para:
3a - 9 (2)
NRC Status: Closed per 80-38 A46 Cat. 1 Structural Steel Material Due Date 12/31/80 Reso:
J. L. Hawks Certifications are being reviewed for D. Muscente comoliance with code and project STP Status: Complete requirements.
NRC Status:
Open Ref. Para:
3a - 9 (2)
A47 AWS Welding Procedures are also being Due Date 12/31/80 Reso:
J. L. Hawks reviewed for compliance with code and D. Muscente project requirements by comparison STP Status: Comolete against primary documents (i.e. AWS NRC Status: Closed per 80-38 Code, AISC Manual & Design Specifications)
Ref. Para: 3a - 9 (2)
A46 For ASME Piping Weld Documentation has Due Date 6/30/80 Reso:
J. L. Hawks been compiled (from isometric DWGS, D. Muscente TRD's, Weld Data Cards, etc.).
STP Status: Complete.
Ref. Para:
3a - 11 (1)
NRC Status: Closed per 80-38 A49 Evaluations are being made for each Due Date 12/31/80 Reso:
J. L. Hawks weld based on information obtained in D. Muscente other task (review of NDE procedures, STP Status: Complete inspector qualification reevaluation NRC Status: Closed per 80-38 of existing R/T etc.).
j Ref. Para: 3a - 11 (1) 1 1
ASC ASME Piping Walkdown will be performed Due Date 12/31/80 Resp:
J. L. Hawks to physically verify information D. Muscente collected in the ASME Piping Weld STP Status: Comolete - Review completed by Documentation Review.
Review Team.
Further review i
Ref. Para:
3a - 12 (1) deemed unnecessary subseauent I
to decision to re-examine all accessible field welds 100%.
NRC Status: Closed per 80-33 i
SHOW CAUSE CO VIMITMENTS EDITION 04-08-81 Page A-11 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A51 Fuel transfer tube and steam generator Due Date 12/31/80 Resp:
J. L. Hawks supports are being investigated to D. Muscente verify the basis on which changes were STP Status: Complete made in Code Classification Material NRC Status: Closed per 81-06 Traceability and Inspection / Hydro Testing.
Ref. Para: 3a - 12 (1)
A52 Approximately 1300 ASME welds have Due Date N/A Resp:
J. L. Hawks been completed or are in process and D. Muscente applicable weld data has been STP Status: Complete collected.
NRC Status: Closed per 81-06 Ref. Para: 3a - 12 (2)
A53 Technical Review of the data collected Due Date 12/31/80 Resp:
J. L. Hawks on pipe welds will continue to
- 0. Muscente completion.
STP Status: Complete Ref. Para: 3a - 12 (2)
NRC Status: Closed per 81-06 AS4 A review of pipe supports and hangers Due Date 12/31/80 Reso:
J. L. Hawks will commence as soon as the task on D. Muscente pipe welds is complete.
STP Status: Complete - Review completed by Ref. Para: 3a - 12 (2)
Review Team.
Further review deemed unnecessary subsequent to decision to re-examine all accessible field welds 100%.
NRC Status: Closed per 81-06 A55 The investigation of the NRC concerns Due Date 12/31/80 Reso:
J. L. Hawks regarding tne fuel transfer tube and D. Muscente steam generator supports is in STP Status: Complete progress.
NRC Status: Closed per 81-06 l
Ref. Para:
3a - 12 (2) t A56 The review of welder qualifications is Due Date 12/31/80 Resp:
J. L. Hawks performed Dy reviewing welder D. Muscente qualification test
- records.
STP Status: Complete Ref. Para:
3a - 13 (1)
NRC Status: Closed per 80-38 A57 Continuity of certification is oeing Due Date 12/31/80 Resp:
J. L. Hawks checked against employment records for D. Muscente welders.
STP Status: Complete Ref. Para:
3a - 13 (1)
NRC Status: Open
SHOW CAUSE COMMITVIENTS EDITION 04-08-81 Page A-12 COMMITMENT REF. P ARA.
DUE DATE RESPONSIBILITY STATUS A58 The associated Certified Material Test Due Date 12/31/80 Resp:
J. L. Hawks Reports will be reviewed for code D. Muscente compliance and the material type will STP Status: Complete be checked against that required by NRC Status: Open the welding procedure specification.
Ref. Para:
3a - 13 (1)
A59 The system for controlling Due Date 10/15/80 Reso:
J. L. Hawks distribution of the filler metal will D. Muscente be reviewed for code and toecification STP Status: Complete. Ref. 17ECP-8 compliance.
NRC Status: Closed per 81-03 Ref. Para: 3a - 13 (1)
A60 Two irregularities in procedures:
1)
Due Date 10/18/80 Reso:
J. L. Hawks use of film side versus source side D. Muscente penetrameters on some of the welder STP Status: Complete - See Nutech letter coupons tested; 2) use of less BR0-01-005 dated 10/17/80 and stringent ASME acceptance criteria memo GM-75698 instead of the AWS acceptance criteria NRC Status: Closed per 81-06 for tne AWS test coupons. These concerns will be evaluated to determine the acceptable of the affected qualifications.
Ref. Para: 3a - 13 (2), 3a - 14 (1)
A61 Welding filler materials used for Due Date 12/31/80 Resp:
J. L. Hawks safety-related welding, CMTR's will be D. Muscente evaluated for compliance to code and STP Status: Complete project requirements.
NRC Status: Open Ref. Para:, 3a - 14 (2)
A62 Welder qualification records will be Due Date 12/31/80 Reso:
J. L. Hawks completed when all weld data cards D. Muscente nave been reviewed.
STP Status: Complete Ref. Para:
3a - 14 (1)
NRC Status: Closed per 81-06 A63 A review of the " unresolved items" Oue Date 12/31/80 Resp:
J. L. Hawks identified in the NRC Investigation D. Muscente Report is being performed to evaluate STP Status: Complete and resolve the reported concerns.
NRC Status: Open/ Ready for NRC Review Ref. Para:
3a - 14 (3)
SHOW CAUSE CO VIVITMENTS EDITION 04-08-81 Page A-13 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS A64 Past NRC, HL&P, B&R Audit Reports have Oue Date 12/31/80 Retp:
J. L. Hawks been reviewed to determine the extent D. Muscente to wnicn audit deficiencies have been STP Status: Complete properly dispositioned.
NRC Status: Open Ref. Para: 3a - 14 (4)
A65 Field Generated Reports (NCR's, Due Date 12/31/80 Reso:
J. L. Hawks FREA's and CAR's) have been reviewed D. Muscente to verify that each has been properly STP Status: Comolete dispositioned.
NRC Status:
Partial closure 81-04 Ref. Para:
3a - 15 (1)
A66 The PSAR/FSAR and Engineering Due Date 7/18/80 Reso:
J. L. Hawks Specifications nave been reviewed to T. J. Natarjan identify the apolicable edition and STP Status: Comolete.
DCN to TRD addenda for all specified codes and 5A700GP004 includes results.
standards.
NRC Status: Closed per 80-38 Ref.
Para:
3a - 15 (1)
A67 Tne Construction and QC Procedures Due Date 12/31/80 Reso:
J. L. Hawks (current and past revisions) covering D. Muscente safety-related pioing and Cat. 1 STP Status: Comolete Structural Steel are Deing reviewed NRC Status: Closed per 80-38 for consistency and compliance to project requirements.
Ref. Para:
3a - 15 (1) l l
A65 Past audits and field generated Due Date 12/31/80 Reso:
J. L. Hawks documents sucn as NCR's FREA's, and D. Muscente l
CAR's related to welding are being STP Status: Complete reviewed.
NRC Status: Open Ref. Para: 3a - 15 (2)
A69 An initial review of field generated Due Date 12/31/80 Reso:
J. L. Hawks documents has been completed, but an D. Muscente evaluation of the,information gathered STP Status: Complete is required.
NRC Status:
Partial closure 81-04 i
Ref. Para:
3a - 15 (2) l A7C Tne Engineering Specifications and Due Date 12/31/80 Reso:
J. L. Hawks Construction Procedures nave been D. Muscente l
l reviewed for consistency and STP Status: Comolete l
compliance with PSAR/FSAR.
NRC Status: Open Ref. Para:
3a - 16 (1) l l
SHOW CAUSE COMMITMENTS EDITION 04-08-81
_8_1 Page A-14 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS JS All Cat. 1 Structural Steel Accessible Due Date N/A Reso:
W. J. Friedrich Welds will be visually re-examined by STP Status: Complete - Task Force Review inspectors who have been retrained to Team recommended 100%
be the AWS Code D1.1-75 with special re-examination. Decision was emphasis on the detailed requirements of the code.
made to re-examine and repair 100% of all accessible welds.
Ref. Para: 3a - 17 (1)
Program is in progress.
NRC Status: Closed per 80-38 AWS training will also include a Que Date 9/22/80 Resp:
W. J. Friedrich detailed review of the welding and NDE STP Status: Complete - Training to be Procedures which include code and continue for QC Inspectors design specification requirements.
until adequate staffing is Ref. Para:
3a - 17 (1) available.
NRC Status:
Closed per 80-38 Tne results of the examination will be Due Date N/A Reso:
J. L. Hawks evaluated and accessible welds will be D. Muscente repaired as required.
STP Status: Complete - Task Force Review be Ref. Para:
3a - 17 (1)
Team recommended 100%
re-examination. Decision was i
made to re-examine and repair 100% of all accessible welds.
Program is in progress.
NRC Status:
Closed per 80-38 The weld characteristics and other Due Date N/A Resp:
J. L. Hawks i by l
pertinent information will be D. Muscente
!W l
statistically classified for use in an STP Status: Complete - Information will be ant
(
engineering analysis of inaccessible developed during III welds to determine their re-examination of existing 5-l acceptability.
Ref. Para:
3a - 17 (1)
NRC Status:
Open ASME ECW Pipe Welds, the B&R and Task Due Date 9/27/80 Reso:
J. L. Hawks 1
Force Level III will review the R/T T. J. Natarjan art.
film found to have unacceptable STP Status:
Complete - Re-radiograph all indications in order to de'termine the walds requiring repair.
accessible welds (not in or I
under structures) See Nutech Ref. Para:
3a - 18 (1) letters DTU 80-002/9-22-80 and DTU-80-20/10-29-80 and memo i
GM-75698 NRC Status: Closed per 80-38 n
ters mc l
e.
SHOW CAUSE COlV VilTMENTS EDITION 04-08-81 Page A-16 ITEM COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS NO.
A82 All accessible ASME Socket Welds and a Due Date N/A Reso:
J. L. Hawks large sample of butt welds will be D. Muscente reexamined.
STP Status: Complete - Information will be Ref. Para:
3a - 19 (1) developed during re-examination of existing welds.
NRC Status: Closed per 81-06 A83 All rejectable indications will be Due Date N/A Resp:
J. L. Hawks repaired unless the welds are embedded D. Muscente in concrete Welds buried in concrete STP Status: Complete - Information will be an engineering evaluation will be developed during performed to determine the necessity re-examination of existing of repair.
Ref. Para:
3a - 19 (1)
NRC Status: Closed per 81-06 A84 ASME NF and Hanger Weld Documentation Due Date N/A Resp:
J. L. Hawks will be reviewed and evaluated.
D. Muscente Ref. Para: 3a - 19 (2)
STP Status: Comolete NRC Status: Closed per 81-06 A85 A sample of the support and hanger Due Date N/A Reso:
J. L. Hawks welds will be reexamined to determine D. Muscente overall condition of the welds.
STP Status: Complete - Review completed by Ref. Para:
3a - 19 (2)
Review Team. Further review deemed unnecessary subsequ'ent to decision to re-examine all accessible field welds 100%.
NRC Status: Closed per 81-06 A86 NF Support and Hanger Welds performed Due Date N/A Reso:
J. L. Hawks by unqualified personnel will be D. Muscente repeated.
STP Status: Complete - Review completed by Ref. Para:
3a - 19 (2)
Review Team. Further review deemed unnecessary subsequent to decision to re-examine all accessible field welds 100%.
NRC Status: Closed per 81-06 A87 A gradus 1 restart on a controlled Due Date 9/12/80 Resp:
J. L. Hawks basis in accordance with a step by Don Muscente step program of planned activities has STP Status:
Complete.
See ST-HL-AE-555 ber.n prepared.
NRC Status:
Closed per 80-38 Pef. Para:
3a - 19 (3)
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-17 COMMITMENT REF. PARA.
DUE DATE ~ RESPONSIBILITY STATUS A88 Witn respect to RCB's which are the Due Date 12/15/80 Reso:
J. L. Hawks first category of structures under G. R. Murphy review, the Task Force and Consultants STP Status: Complete - See ST-HL-AE-513 Panel are examining internal ST-BR-HL-36470 placements.
NRC Status: Closed per 80-38 Ref. Para:
3b - 3 (3) l A89 The Task Force and Consultants Panel Oue Date N/A Reso:
J. L. Hawks are reviewing the results of previous G. R. Murphy HL&P/8&R investigations of the RCB STP Status: Complete. Ref: ST-HL-AE-513 shells.
NRC Status: Closed per 80-38 Ref. Para:
3b - 3 (3)
A90 A list of unresolved concerns Due Date 12/15/80 Reso:
J. L. Hawks previously identified in NRC HL&P &
G. R. Murphy d&R Audits have been compiled.
STP Status: Complete - See ST-BR-HL-36470 Ref. Para:
3b - 3 (4), 3b - 4 (1)
NRC Status: Closed per 80-38 A91 Unresolved concerns will be addressed Due Date 12/15/80 Resp:
J. L. Hawks either in the normal course of the G. R. Murphy review or througn special STP Status: Complete - See ST-HL-AE-513 investigation.
ST-BR-HL-36470 Ref. Para: 3b - 4 (1)
NRC Status: Closed per 81-03 A92 TRO 2A700GP003 " review of Due Date N/A Reso:
J. L. Hawks safety-related concrete structures G. R. Muroty including embedments" will be updated STP Status: Complete periodically to incorporate changes in NRC Status: Closed per 80-38 and results of the program.
Ref. Para: 3b - 4 (2)
A93 UT testing of concrete has found one Due Date 8/15/80 Reso:
J. L. Hawks (1) discrepancy (appears to be due to G. R. Murphy surface condition) which is being STP Status: Complete. Ref: ST-HL-AI-513.
furtner investigated and is expected to be resolved shortly.
NRC Status: Closed per 81-03 Ref. Para:
3b - 4 (3)
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-18 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A94 To assure all documentation has been Due Date 10/31/80 Reso:
J. L. Hawks performed, all test reports, batch G. R. Murphy plant records, pour cards, inspection STP Status:
Review is complete - GM-75289 reports, drawings, DCN's, FREA's, See - ST-BR-HL-36470 NCR's, and CAR's which pertain to NRC Status: Closed per 81-03 selected placements are being reviewed and evaluated as to their correctness and completeness.
Ref. Para: 3b - 7 (2)
A95 Test reports are being evaluated for Due Date 12/15/80 Reso:
J. L. Hawks l
the cement admixture, aggregates and G. R. Murphy water used, as well as slump, air STP Status: Complete - See St-BR-HL-36470 content, compressive strength, unit NRC Status: Closed per 81-03 weight and concrete temperature.
Ref. Para:
3b - 7 (2)
A96 Each report is being checked for Due Date 10/31/80 Reso:
J. L. Hawks completeness, design compliance, and G. R. Murphy for proper signature of initials.
STP Status:
Review is complete - GM-85289 Ref. Para:
3b - 7 (2)
See - ST-BR-HL-36470 l
NRC Status: Closed per 81-03 A97 Batch plant records are being Due Date 12/15/80 Reso:
J. L. Hawks evaluated for completeness of record, G. R. Murphy proper signatures or initials, and STP Status: Complete - See ST-BR-HL-36470 l
compliance witn applicable procedures.
NRC Status: Closed per 81-03 Ref. Para:
3b - 7 (2)
A98 Pour cards are being checked for QC Due Date 12/15/80 Resp.
J. L. Hawks signatures, listing of NCR's, FREA's, G. R. Murphy DCN's, and drawings, and notations of STP Status: Complete - See ST-BR-HL-36470 otner unsatisfactory conditions which NRC Status: Closed per 81-03 I
snould have resulted in the issuance l
of an NCR.
l Ref. Para: 3b - 7 (2)
A99 Preplacement, placement, and curing Due Date 12/15/80 Resp:
J. L. Hawks inspection checklist are being G. R. Murphy reviewed for proper signatures, time STP Status: Complete - See ST-BR-HL-36470 l
span between preplacement inspection NRC Status: Closed per 81-03 and of pour, and notations of other unsatisfactory condition which should nave resulted in issuance of NCR.
I Ref. Para:
3b - 7 (2), 3b - 8 (1) l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 08-81 Page A-19 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS
.TUS ihere available, punchlist are also Due Date 12/15/80 Resp:
J. L. Hawks ning evaluated for proper signoff of G. R. Murphy nacn item.
STP Status: Complete - See ST-BR-HL-36470 lef. Para:
3b - 8 (1)
NRC Status: Closed per 81-03
%s designed documents (including Due Date 12/15/80 Reso:
J. L. Hawks 1CR's, FREA's, drawings, and DCN's)
G. R. Murphy are being evaluated to determine where STP Status: Complete - See ST-BR-HL-36470 avery embedment, penetration, anchor NRC Status: Closed per 81-03 solt, construction joint, opening and dimension change should be located.
Ref. Para: 3b - 8 (2)
The "as-built" inspection program Due Date 12/15/80 Resp:
J. L. Hawks consist of obtaining field G. R. Murphy measurements for: placement location STP Status: Complete - See ST-BR-HL-36470 and dimensions (tnickness, openings, NRC Status: Closed per 81-03 plumbness, squareness, size, and idsntification if available).
Ref. Para: 3b - 9 (2)
Once tne "as-built" condition is Due Date 12/15/80 Reso:
J. L. Hawks documented, it will be compared to the G. R. Murphy "as designed" condition and all STP Status: Complete - See ST-BR-HL-36470 discrepancies will be identified.
NRC Status: Closed per 81-03 Rcf. Para: 3b - 9 (2) l Visual inspection is being performed Due Date 12/15/80 Resp:
J. L. Hawks 5470 by the Special Consultants Panel and G. R. Murphy l
selected examiners from the Task Force STP Status: Comolete - See ST-BR-HL-36470 l
and addresses the following areas:
NRC Status: Closed per 81-03
- 1) General appearance of the surface
- 2) Nature and extent of cracking
- 3) Evidence or volume change
- 4) Evidence of cement /aggreget l
reactions date
- 5) Secondary deposit on surface gn
- 6) Secondary deposits in cracks or TRD voids
- 7) Construction joint alignment
- 8) Construction joint cleanliness
- 9) Control joints
(
.0) Tne nature and extent of I
deflections u
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-21 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A107 The Consultants Panel is to also Due Date 12/15/80 Resp:
J. L. Hawks visually examine every core obtained G. R. Murony to evaluate the qt ality of STP Status: Complete - See ST-HL-AE-513 consolidation and uniformity of the ST-BR-HL-36470 concrete.
NRC Status: Closed per 81-03 Ref. Para:
3b - 11 (1)
A108 The Consultants Panel is to direct the Due Date 12/15/80 Resp:
J. L. Hawks drilling of probe holes and using G. R. Murphy
~
fiberoptics visually examine the holes STP Status:
Complete - See ST-BR-HL-36470 to evaluate the quality of NRC Status; Closed per 81-03 consolidation.
Ref. Para:
3b - 11 (1)
A109 Selected cores, in addition to visur.1 Oue Date 12/15/80 Resp:
J. L. Hawks examination, are to be examined using G. R. Murony petrograonics and microscopial STP Status: Complete - See ST-BR-HL-36470 tecnniques.
NRC Status: Closed per 81-03 Ref. Para:
3b - 11 (1) l A110 The Consultants Panel is to address Oue Date 12/15/80 Resp:
J. L. Hawks previous unresolved concerns and G. R. Murony allegations by visually inspecting STP Status: Complete - See ST-BR-HL-36470 such areas and recommending specific NRC Status: Closed per 81-03 test wnere such methods would resolve specific concerns or allegations.
Ref. Para: 3b - 11 (1) t l
l Alli The sonic correlations and reference Due Date 12/15/80 Reso:
J. L. Hawks standard are being developed on the G. R. Murony sample area utilizing cores or bore STP Status: Complete - See ST-BR-HL-36470 holes wnere possible.
NRC Status: Closed per 81-03 Ref. Para: 3b - 12 (1) i All2 To provide assurance that on-going Due Date N/A Reso:
J. L. Hawks safety related concrete work is G. R. Murphy I
meeting all requirements, HL&P/B&R STP Status: Complete have completed a review of all New Procedures issued concreted inspection procedures and NRC Status: Closed per 80-38 i
applicaple training procedures independent of special task force.
Ref. Para:
3b - 15 (1) t
SHOW CAUSE COMMITMENTS EDITION 04-08-81
~
Pace A-22 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS TUS Q.C. inspectors have been added to Due Date N/A Reso:
W. J. Friedrich ch assure that proper preplacement STP Status: Complete.
,y*
~
inspections are being conducted.
NRC Status: Closed per 80-38 lif. Para:
3b - 15 (3)
Revised procedures are now in place Due Date 7/21/80 Reso:
K. Cook and retraining is being performed STP Status:
Procedures implemented and ich 4here necessary.
training accomplished 7/21/80.
lef. Para:
3b - 15 (2)
NRC Status: Closed per 80-38
- onsolidation refresher training is Due Date N/A Resp:
R. H. Leasburg low required every 90 days for STP Status: Complete.
- onsolidation placement craft NRC Status: Closed per 80-38 3ersonnel.
Ref. Para: 3b - 16 (1) ich stop work authority of Q.C. inspectors Due Date 8/25/80 Reso:
W. J. Friedrich is being emphasized in training of STP Status: Complete; ST-QAP-15.2 issued
)roject personnel.
8/15/80.
lef. Para:
5 - 5 (3)
NRC Status: Closed per 80-27 ich juality Engineering (QE) will Due Date N/A Reso:
W. J. Friedrich
)diticipate in Construction planning STP Status:
Inspection points delineated ind will determine inspection hold in CCP-25.
Joints for work activities.
NRC Status: Closed per 80-27 (ef. Para:
6 - 2 (3) y
).E. will determine insoection Due Date N/A Reso:
W. J. Friedrich
- haracteristics required and record STP Status: See A117 above.
- hem on Inspection Reports, (IR) to be NRC Status: Closed per 80-27 ised by QC Inspectors.
tef. Para:
6 - 2 (3) ich JC inspectors will record results of Due Date N/A Reso:
W. J. Friedricn ill planned inspectio.:s on I.R.
The STP Status: See A117 above.
..R. will be a permanent QA record.
NRC Status: Closed per 80-27
- ef. Para:
6 - 3 (2)
.j en
.y, 1,
ICR's will be ar.xnowledged by the Due Date 9/15/80 Resp:
W. J. Friedrich
.ignature of tne construction foreman STP Status: Complete - STP-QAP-15.1 ir general foreman.
NRC Status:
Closed per 80-27
- ef. Para:
6 - 4 (2), 6 - 5 (1)
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-24 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A128 Trend analysis performed by DAG will Due Date 9/15/80 Reso:
W. J. Friedrich be made available to HL&P QA.
STP Status: Complete - on-going Ref. Para: 6 - 10 (3)
HRC Status: Closed per 80-27 A129 HL&P QA will utilize the B&R data and Due Date 11/1/80 Reso:
R. A. Frazar other data collected by HL&P STP Status: Complete - ongoing surveillance and audits to perform an NRC Status: Closed per 80-27 independent trend review and report results to upper management.
Ref. Data: 6 - 10 (3)
A13C All design changes proposed at the STP Due Date 10/1/80 Reso:
R. W. Peverley Site will be submitted to Project Site STP Status: Complete - GCP-21 effective Engineering.
10/1/80 Ref.
Para:
7 - 2 (2)
NRC Status: Closed per 81-05 A131 Qualification and training records Due Date 10/31/80 Resp:
R. W. Peverley will be maintained on Project Site STP Status: Ongoing - Records will be Engineers and Q.E.'s transferred to jobsite by, Ref. Para:
7 - 2 (2) 12-15-80 NRC Status: Open/ Ready for NRC Review ;
A132 Copies of DCN's will be issued to Due Date 10/1/80 Resp:
R. W. Peverley i
Board Members prior to each meeting.
STP Status: Complete Ref. Para: 7 - 5 (1)
NRC Status: Closed per 81-05 A133 Board Chairman will sign DCN Due Date 10/1/80 Resp:
J. L. Hawks signif ing approval.
STP Status: Complete - Ref. STP-DC-029 f
Ref. Para: 7 - 5 (1) effective 10/01/80 NRC Status: Closed per 81-05 A13a Tne ce rently use,FREA will be Due Date 10/1/80 Reso:
R. W. Peverley eliminated.
STP Status: Comolete - Ref. STP-DC-023 and Ref. Para:
7 - 5 (2)
GCP-21 NRC Status: Closed per 80-36 l
l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-25 l
COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS 1
A135 Each day a description of each DCN Due Date 10/1/80 Reso:
R. W. Peverley processed that day will be entered STP Status: Complete - Ref. STP-DC-028 into a computer by engineering NRC Status: Closed per 81-05 personnel at the Site and in the Houston office.
Ref. Para:
7 - 7 )2)
A136 Each morning, a computer printout will Due Date 10/1/80 Resp:
R. W. Peverley be provided to users of the design STP Status: Complete - Example GM-75178 documents.
NRC Status: Open/ Ready for NRC Review Ref. Para:
7 - 7 (2)
A137 When construction of an item has been Due Date 10/1/80 Reso:
R. W. Peverley completed verification checklist will STP Status: Complete be prepared and their correctness will NRC Status: Open be verified by Design and Qualitf Engineer. This checklist will be used by the inspector for final acceptance.
Ref. Para:
7 - 7 (3), 7 - 8 (1)
A138 During first few weeks of new program Due Date 10/1/80 Reso:
R. W. Peverley no FREA's will be issued.
STP Status: Complete - Ref. STP-0C-023 and Ref. Para:
7 - 8 (5)
GCP-21 NRC Status: Closed per 80-36 A139 Evaluation of a program to be Due Date 10/31/80 Resp:
R. W. Peverley l
performed to determine if minor STP Status: Complete t
changes are required.
NRC Status: Open l
Ref. Para:
7 - 8 (6), 7 - 9 (1)
A140 Any FREA not approved by October 1, Due Date 10/31/80 Reso:
R. W. Peverley 1980 will be handled as FCR and STP Status: Complete l
procesed accordingly.
NRC Status: Open Ref. Para:
7 - 9 (1) l l
A141 A system will be created by Quality Due Date 11/1/80 Resp:
W. J. Friedrich Engineers such that, prior to STP Status: Complete - Ref. ST-QAP-10.1 commencement of work, the records op. 4.1, 4.4, 4.5, 4.5.1, and required to substantiate the 4.5.2 and 9"P-1 Sec. 10 individual activities will be NRC Status: Open/ Read # 'or NRC identi fied.
Ref. Para:
8 - 2 (6)
I 1
1
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-26 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS A142 Persons charged with creating required Due Date 11/1/80 Resp:
W. J. Friedrich documents will record the status of STP Status: Complete - Ref. ST-QAP-17.1-2 those documents as the documents are Sec. 3.1.4 and 3.1.5 created.
NRC Status: Open Ref. Para: 8 - 2 (6), 8 - 3 (1)
A143 When completed document packages on Due Date 11/1/80 Resp:
W. J. Friedrich individual activities are completed in STP Status: Complete - Ref. ST-QAP-10.1 tne QA Vault, Quality Engineering will op. 4.5 review them to verify the documents NRC Status: Open are complete'and adequate.
Ref. Para:
8 - 3 (1)
A144 New microfilm equipment is being Due Date 10/1/80 Resp:
W. J. Friedrich acquired to speed up filming.
STP Status: Complete Ref. Para: 8 - 3 (2)
NRC Status: Closed per 81-05 A14S A on-site film processing laboratory Due Date 10/1/80 Resp:
W. J. Friedrich devoted to QA needs is being STP Status: Complete - Bldg. in place and establisned.
3 people trained Ref. Para: 8 - 3 (2)
NRC Status: Closed per 81-05 A146 A new filing system is being Due Date 10/1/80 Resp:
W. J. Friedrich l
implemented to eliminate the various STP Status: Complete - eliminated Pre and l
suspense files.
Post microfilm suspense files Ref. Para:
8 - 3 (4)
NRC Status: Closed per 80-36 A147 There will be a single filing system Due Date 11/1/80 Resp:
W. J. Friedrich and the documents will be filed with a STP Status: Complete Ref. NAl-77-149 l
record traveler prepared by Quality NRC Status: Open l
Engineers.
Ref. Para:
8 - 4 (1) l l
l A148 The record traveler will identify the Due Date 11/1/80 Resp:
W. J. Friedrich records required to substantiate each STP Status: Complete - Ref. ST-QAP-17.1 activity, will rec'ord the status of and ST-QAP-10.1 the file, records borrowed from the NRC %:: c Open file and will be used to identify I
averdue and missing records.
j Ref. Para:
8 - 4 (2) i l
l l
SHOW CAUSE COMMITMENTS EDITION 04-08-81 1
Page A-27 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS 3
1 Records already in the vault will be Due Date08/01/81 Reso:
W. J. Friedrich reviewed for adequacy and STP Status: On Schedule completeness, based on the results of NRC Status: Open the review of records requirements.
Ref. Para: 8 - 4 (2)
The B&R Audit Group and Project QA Oue Date N/A Reso:
R. L. Ulrey Management will regularly receive the R. W. Bass 3
reports of the trend Analysis Group.
STP Status: HL&P Ref. Para:
9 - 2 (4)
HL&P is reviewing the HL&P trend on a monthly basis, STP Status: B&R d'
Quarterly.
j NRC Status: Closed per 81-04 nd The HL&P Audit Group and Project Oue Date N/A Reso:
R. L. Ulrey Management QA will revieve both HL&P STP Status:
Ine first trend analyses and B&R trend analyses.
Ref. Para:
9 - 3 (1) issued by HL&P was sent to management as part of the August 1980 monthly report.
Additional reports will be sent on a quarterly basis.
NRC Status: Closed per 81-04, 01 The function of the HL&P Corporate Due Date N/A Resp:
R. L. Ulrey Audit Group has been redefined to STP Status: HL&P Procedures QAP-5, SA, SB, minimize conflicting assignments and and SC have been revised and responsibilities of auditors.
Thereby creating a group who's primary are now in effect.
The HL&P function is to prepare for and conduct organization change which audits of safety-related activities.
assigns a supervisor to the Ref. Para:
9 - 3 (3) audits group reporting to the HL&P QA manager went into
.he effect June 16, 1980.
NRC Status: Closed per 80-27
.'e d s
i e
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-29 COMMITMENT REF. PARA.
DUE DATE RESPONSIBILITY STATUS
)
A156 The quarterly schedule provides for Due Date N/A Reso:
R. L. Ulrey supplemental audits.
R. W. Bass Ref. Para:
9 - 4 (3)
STP Status: HL&P Rev. 4 of audit schedule reflects supplemental audits.
STP Status: B&R 9-15-80.
NRC Status: Closed per 80-27 A157 A matrix has been prepared delineating Due Date N/A Resp:
R. L. Ul rey all B&R procedures applicable to STP R. W. Bass and the corresponding audit to whicn STP Status:
HL&P they apply.
Matrix is on file at QA EDC Ref.
Para:
9 - 4 (3) office and will be updated as B&R procedures are added/ deleted.
STP Status: B&R Complete.
NRC Status: Closed per 80-27 I
A158 inis matrix is utilized by HL&P and Due Date N/A Reso:
R. L. Ulrey l
B&R audit groups to assure all Quality R. W. Bass activities are audited witnin the STP Status: HL&P required frequency.
Matrix was used during HL&P l
Ref. Para:
9 - 4 (3)
Audit BR-30 and will be used l
for HL&P Audit BR-34 STP Status: B&R On-going.
NRC Status: Closed per 80-27 A159 At least one audit team member must be Due Date N/A Resp:
R. L. Ulrey experienced or trained in the R. W. Bass discipline being audited.
STP Status: HL&P Ref. Para:
9 - 4 (4)
During BR-30, a technical advisor was used as a team member. Audits SWF-6, SRI-1, HL-84, WNSD-1, E7C, audit team members were experienced in i
the discipline audited.
STP Status: B&R Incorporated into audit procedure.
NRC Status: Closed per 81-04
SHOW CAUSE COMMITMENTS EDITION 04-08-81 Page A-30 COMMITMENT REF. PAR A.
DUE DATE RESPONSIBILITY STATUS A160 A revised audit schedule and an update Due Date N/A Reso:
R. L. Ulrey of audits conducted in the previous R. W. Bass quarter, including an evaluation of STP Status: HL&P the audits performed are issued each On July 31, 1980,' status was quarter.
issued to the Houston QA Ref. Para: 9 - 5 (1)
Manager.
STP Status: B&R On-going since January 19?>0.
NRC Status: Closed per 80-27 A161 Follow-up audits will be conducted to Due Date N/A Reso:
R. L. Ul rey verify successful correction of R. W. Bass problems and their causer, STP Status: HL&P Ref Para:
9 - 5 (3)
ToTTow-up audits are and will continue to be conducted.
Ref. WPD-5, GE-16, PWRSD-5, HL-87, BR-31, HL-84, BR-35, HL-90, HL-91, HL-86, HL-92, HL-95, BR-37.
STP Status: B&R on-going.
NRC Status: Open/ Ready for NRC A162 The HL&P Corporate Audit Group has Due Date N/A Ress:
R. L. Ulrey been conducting audits of B&R STP Status: HL&P construction activities since March, Audits BR-30 and B3-34 are B&R 1980.
construction audits completed Ref. Para:
9 - 5 (4) or in process. Additional audits are scheduled and due to the stop work in the welding area BR-33 will be conducted at a later date.
NRC Status: Open/ Ready for NRC A163 The matrix of B&R STP Procedures has Due Date N/A Reso:
R. L. Ul rey been prepared and both HL&P and B&R
- o. W. Bass have new schedules of future audits, STP Status: HL&P including time and personnel T F supplemental audits are provisions for the performance of listed on the schedule within supplemental audits.
the time frame by month, Ref. Para: 9 - 6 (1) specific dmtes or activities are not listed until the supplemental audit is requ::sted in accordance witn H' &P procedure.
STP Status: B&R Complete 9/15/80.
NRC Status: Closed per 80-27
.-