ML20023A428
| ML20023A428 | |
| Person / Time | |
|---|---|
| Site: | 05000000, South Texas |
| Issue date: | 09/11/1980 |
| From: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Harold Denton, Shapar H, Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20023A411 | List: |
| References | |
| FOIA-82-603 NUDOCS 8010090450 | |
| Download: ML20023A428 (9) | |
Text
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UNITED STATES f'
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NUCLEAR REGULATORY COMMISSION g
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MEMORANDUM FOR:
Harold R. Denton, Director, FRR Howard K. Shapar, Executive Director, ELD i
Victor Stello, Jr., Director, IE
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FROM:
Harold D. Thornburg, Director, Division of Reactor Construction Inspection. IE
SUBJECT:
COMMISSION INFORMATION PAPER ON THE SOUTH TEXAS PROJECT PLAN FOR RESUMPTION OF CURRENTLY HALTED CONSTRUCTION
.l-Enclosed is a draft of the Comission Infomation Paper which we were requested to prepare addressing the plan for the resumption of construction activities at the South Texas Project. These activities have been halted under the licensee's actions and documented in NRC Imediate Action Letters.
Coments/ concurrences will be needed not later than noon on Friday, September 12, 1980.
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. Thornburg Director Division of Reactor Construction Inspection Office of Inspection and Enforcement
Enclosure:
Draft Comission Paper cc/w enclosure:
R. C. DeYoung, IE J. P. Murray, ELD
. Thompson, IE J. McGurren, ELD W. Reinmuth, IE D. Sells, NRR
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' N(9 V. Seyfrit RIV W. Haass, NRR W. C. Seidle, RIV J. Cumings, OIA S. Phillips, RRI-RIV CONTACT:
R. E. Shewmaker, IE 49-275S1 XA Copy Has Been Senf fojR 0DVp/[O
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e DRAFT 9/H/ZO i
For:
The Commissioners From:
Victor Stello, Jr., Director Office of Inspection and Enforcement Thru:
Executive Director for Operations
Subject:
PLAN FOR THE RESUMPTION OF CURRENTLY HALTED CONSTRUCTION AT E
THE SOUTH TEXAS PROJECT, DOCKET NOS. 50-498/499 c
Purpose:
To inform the Commission of:
1.
the various requirements or commitments that must be met by the licensee, Houston Lighting and Power Company (HL&P),
prior to the resumption of currently halted construction activities, f
2.
the plan of the sequence in which these requirements i.
should be met, and 3.
the current status of the NRC review of the licensee's actions.
Background:
The key events related to the South Texas Project are listed chronologically:
December 31, 1979 - NRC Immediate Action Letter noting,
action of the licensee in halting all complex, safety-related concrete placements.
.c April 15, 1980 - S.revious Commission briefing on the findings of the special investigation conducted from November 10, 1979 through February 7,1980.
April 17, 1980 - NRC Immediate Action Letter noting action of the licensee in halting all ASME Code welding and other i
safety-related welding (B31.7 welding not halted).
l April 28, 1980 - Investigation Report No. 50-498/79-19; 50-499/79-19 reporting the results of the special investi-gation was sent to the licensee.
l CONTACT:
H. D. Thornburg, IE 49-28484 l
5 The ccmmissioners '
April 30, 1980 - Notice of Violation and civil penalty issued for twenty-two (22) items of noncompliance with a cumulative penalty in the amount of $100,000.
April 30, 1980 - Order to Show Cause why all safety-related construction activities should not be stooped in ninety (90) daysuxrs issued..
May 23, 1980 - Licensee response to Notice of Violation confirmed, with minor exceptions, all of the twenty-two (22) items of noncompliance and forwarded payment of'
$100,000 civil penalty.
July 17,1980 - NRC Immediate Action Letter noting the
- 5 actions that could.be taken by the licensee for AWS welder qualification.
July 28,1980 - Licensee response to Order to Show Cause addressed all a,':::n ( H) items specified in the Order.
August 19, 1980 - Public Meeting held at Bay City, Texas including HL&P, Brown & Root, NRC staff and local govern-ment officials, organizations, and members of the public.
Discussion:
A.
Requirements:
The various requirements and commitments which must be met by the licensee originate from several sources as a result of the NRC actions taken over the past nine months.
These sources are as follows:
1.
Three Immediate Action Letters (IALs) 2.
Special Investigation Report
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e 3.
Notice of Violation and Civil Penalty l
4.
Order to Show Cause l
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5.
Public Meeting L
h ea d se = EJ6*ea/F 6.
Written Requests from the NRC For ease of control the various requirements and commitments have been categorized into ten (10) subject areas.
This system is being used both by the licensee and the NRC for consistency.
These categories encompass the various subjects th:t have been addressed throughout the period, beginning with the special investigation.
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Tha-Commissieners.,
Each of'the requirements or commitments is being placed in one of the.abama categories creating a matrix of actions to be completed.
This systematic approach will provide the NRC staff with a good mechanism for monitoring the licensee's actions to assure all items are being completed.
Careful formula-tion and checking of this action control matrix is being performed by Region IV to be certain all necessary items are included.
Briefly, the requirements which must be met are listed in general terms in the following numbered categories.
The detailed, specific requirements will A
be defined in the NRC's action control matrix.
~ 1.
QA Program - Organization: A review and evaluation of the existing QA organization (late 1979)-of HL&P, Brown and Root and other contrac-tors and subcontractors, as appropriate, are being made.
Experienced management /QA consul-tants are being used.
The licensee is to take actions to revise the QA program organization based on the recommendations and the experience f
already gained at the South Texas Project site.
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Documentationofthechangesto,jhfgewsoAyo tpe shall be made /4 f.9c 754A fe p
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2.
QA Program - Allegations /Harrassent: An assess-ment is being made through all levels of the work environment to attempt to determine the cause of the allegations and concerns of harass-
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ment.
A procedure to address the resolution of conflicts which may arise between personnel in 3
l production and quality disciplines fr x rr"r-9 seweses.is being developed and implemented.
_.c 3.
QA Program - Trending / Document Control:
A systematic program to assess the significance of the various nonconformances, deficiencies, deviations, changes etc.
and determine if l
trends are apparent is being developed.
This program will also address the subject of document 1.
control and its adequacy since documentation will provide the bulk of the source material for trending.
Implementation of this phase of the program must be, demonstrated. Fe., =4n/.2dW 4 71s'a En-ic //c 4 h
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f QA Program - Audits / Surveillance: A review of audits defined in the HL&P QA program is being made and the execution of required audits will
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begin on a prescribed schedule.
The lack of a i
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The Comissieners '
project' requirement for HL&P audits on QA procedures and construction procedures is' being corrected'in the program.
Implementation of this phase of the program must be demonstrated.#-> 4 in rie n., n,a 3 y,. s.
, s r:. t. i n
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0-5.
kK' Program
' Personnel Qualifications: A review and evaluation of QA/QC personnel qualifications are being completed and any necessary requalifi cation.is being performed.
- d 6.
QA Program - Welding: A review and evaluation of previous NDE requirements and personnel require-ments are being completed to define past errors g
and to provide i.
t into a corrective program which will be'
' Implementation of the corrective action and a properly functioning
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program must be demonstrated. %
7.
Construction /QC - Concrete Procedure Revisions:
A review and evaluation with necessary revisions to site procedures are being completed to incorporate controls on additional corrective work in areas already accepted.
This is also f
being done to incorporate a new format in proce-dures for ease of use and defining involvement
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of craft supervisors.
Implementation of these revised procedures will be demonstrated.
8.
Construction - Backfill / Soils Testing: A review and evaluation of records supplemented with necessary additional field observations / testing are being completed to provide an assessment of the adequacy of the inplace structural backfi,ll and soils testing.
Any procedures found deficient as a re uit o
((pag'on e to be Ask b revised. b y cien HN6' je serrected.
A A( afgM 1r 9.
Construction - Concrete:
rdview and evaluation of records and examination, including areas of known problems and as defined by existing records, are being completed to assess the adequacy of the existing concrete structures.
Corrective actions are to be definedy in procedures which arethentobedemonstrat.edduringimplementation,4 c',; 11[es c.;.y Necessary concrete repairsse of,.
be awu 10.
Construction - Welding: A review and evalur. tion of records and non-destructive examir.ations are being performed on the work completed to date in order to assess the adequacy of the existing work.
Corrective actions as required will be
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. The Commissioners.a made including any necessary welding procedure l
changes or rework of existing welds.
B.
Staging / Sequence:
Since logically.some corrective elements must be completed before segments of the currently halted safety-related work can resume, the staff has specifically defined, in.a general sense, those key, l
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A4 spects of the rganizatiorgmust be
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acceptable to.the sta It is necessary that the organization be clearly defined, responsibili ~ j ties clearly delineated and authority properly vested.. Interfaces between.the various organiza-tions must be clearly ined. An assessment must be made by the s
'tfie ability of the licensee's organization t eet 10 CFR 50, Appendix B.
cenhaue 40 YAe 2.
A.14 actions necessary to correct the cause of the continuous and repeated allegations dealing 7-with harrassent, threats and lack of management
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support are to be completed and an assessment made by the staff that all aspects have been
' implemented or will be implemented if the need arises.
3.
All new procedures or revisions covering defect trends and document control are to be issued and demonstrated by implementation.
The staff will have to make a finding with respect to the adequacy of the licersee's actions.
4.
All new procedures or revisions addressing the problems found in audits and surveillances are to be issued and demonstrated by implementation, or shown to be ready for implementation.
The staff will make an assessment of the licensee's actions.
4--
In the remaining facets the sequence can proceed on a work discipline basis, but without any fixed order for the staging of, war $ 4btg jm/y,m; licensee., Where the levej of acti
% de1.ineated all requirements must be 1'ines*
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The Comissioners '
5.
The qual'ifications of personnel involved in executing the QA program must have been reviewed and determined to meet the appropriate require-ments.
The staff will make an assessment of the licensee's actions.
6.
All necessary revisions in the welding QA program eN'fsh'o"m."$' Sha h fmY4e $ bv Y k 0 conifeY$nsTr c#Nn procedures must have 7.
t been revised to simplify and clarify them for ni b t
bility of these procedures.
'I 8.
Nearly all soil backfill has been placed and the problem is considered of less magnitude than initially concluded from the site records examined during the special investigation.
Thus soil backfill work may continue using new revised procedures once those procedures have been reviewed by the staff.
The questions in the soils area which were not asked by the staff f
during the public meeting still require licensee response.
When this action is completed and a
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staff evaluation is completed the issue on soils and foundations will be considered completed.
9.
Certain actions defined in IALs specifically related to concrete construction must be completed prior to the resumption of complex concrete placements.
In addition, all known defects must be located, defined and categorized prior to commencing complex concrete placements.
Tne defects can be addressed building by building or by working from the foundation upwards.
The staff will provide an assessment of the I
licensee's actions at various steps to support as much as possible the licensee's schedules.
The staff will also provide an assessment of the existing structural integrity of the buildings prior to the restart of complex concrete placement.
10.
Certain actions defined in IALs specifically related to welding must be completed.
All problems identified in existing work will be corrected as necessary.
All completed safety-related welding work is to be reviewed for defects.
Work may begin when certain systems,
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The Commission:rs '
components or structures have had these reviews completed.
The staff will provide findings concerning the licensee's action.
As various increme'nts of work are able to proceed, IE will issue, through Region IV, an Immediate Action Letter, defining and describing the work which is authorized.
If problems arise, an Order could be is.ued to obtain the proper licensee actions.
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[ [ t Status:
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Curren
' Meetings have taken place, certain
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g documents have been furnished by the licensee and some inspections have been performed.
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Meetings -
June 16, 1980 - with RIV on Order June 30, 1980 - with RIV on Order June 30, 1980 - with HQ on QA Organization and g
general assessment
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of NRC action July 3,1980 - with RIV on Order Se M ber EET.n seAccloles ad Documents,la,igso-s #tA)R.C rewerdel closeo
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Various 50.55(e) reports addressing findings as a result of Order and Notice of Violation.
Summaryofcompletalcommitments ready for NRC review,4gosf-2g,89Po.
kchedulesforcompletionof work items such as review of concrete placements.
Inspections -
June 23-26, 1980:
Soils July 22-24, 1980:
Soils and Concrete items from the special investigation e
A.
I 2
4 The Coraissioners
- 8 Scf&cr 2-Sp10 '
Nsk lGrusy* "ff Am July 28-29, 1980:
Disposition of Certain NCRs.
t 1980: /MMew/.IP
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/Y00-ime five $C)@'Ttems of-
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At the present noncomplianck ne ($) unresolved items (1) Shn C r : Ort r 'tr have mad aaa been resolved.
The licensee is continuing to pursue the reviews and inspections to which his responses committed, and in the near future will provide proposed schedules for resumption of work in those areas presently under self imposed stop-work orders.
These schedules are dependent upon completion and implementation of revised work and inspection procedures, and presentation of the details of reinspection and repair programs to which the licensee committed in his written and oral bk response made during the August 19,t980 g e.
meeting.
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Resources:
1 4' An estimate of 550 inspector-hours will be required to review and evaluate corrective action pertaining to QA/QC
' program deficiencies which includes effectiveness of changes to the QA organization structure with regard to independence; procedure revision; surveillance and audit effectiveness; and control of field design changes and nonconformance reporting.
An additional 450 inspector-hours will be required to complete direct observation of
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work associated with resumption of AWS and ASME welding of Class I structures and piping, and placement of complex concrete.
Coordination:
This paper has been concurred in by the Offices of Nuclear Reactor Regulationpaed.the Executive Legal Directorfss no
,g./cpec//en t
Victor Stello, Jr.
Director Office of Inspection and Enforcement WPU:SM 9/10/80 JOB L (RES3)
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