ML20023C922
| ML20023C922 | |
| Person / Time | |
|---|---|
| Site: | 05000000, South Texas |
| Issue date: | 09/18/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20023A411 | List: |
| References | |
| FOIA-82-603 NUDOCS 8305180326 | |
| Download: ML20023C922 (11) | |
Text
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.....,i gp 3,81980 MEMORANDUM FOR: William J. Dircks Acting Executive Director for Operations FROM:
Victor Stello, Jr., Director Office of Inspection and Enforcement
SUBJECT:
CONSTRUCTION AT SOUTH TEXAS PROJECT You may be aware that the subject, partly covered by the enclosed paper, is
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the basis of a request for hearing by intervoors and thus has ex-parte considerations for the Chairman.
On that basis the Chairman has rea,uested the paper be forwarded through
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L. Bickwit, General Counsel.
Victor Stello, Jr.
Director Office of Inspection and Enforcement
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Enclosure:
Connission Paper "f.S
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-For:
- The Commissi~oners-7
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From:
Victo'r Stello; 'Jr., ~ Director Office of Inspection and Enforcement
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Thru:.
' ' - Executive Difact'or for Operations'
Subject:
PLAN FOR THE RESUMPTION OF CURRENTLY HALTED CONSTRUCTION AT THE SOUTH TEXAS PROJECT, DOCKET NOS. 50-498/499 l
Purpose:
To inform the Commission of:
- 1.
.the 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, ss-2.-
the ' plan of the sequence in which these requirements should be met, and.
i 3.
/the current status of-theLNRC review of the licensee's' s'~,
~ actions.
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s
[l Backaround:
The key eventsfrelated to the South Texas Project 1re listed
- chronologically
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December 31, 1979 - NRC'Immediate Action Letter noting action of the licensee. in halting all complex, safety-related concrete placements.
April 15, 1980 - Commission briefing on the findings of fthe 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 ASHE Code welding and other safety-related welding'(B31.7 welding not halted).
April'28, 1980 - Invest'igation 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 49-24484 l
l The Commissioners 2-s 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 stopped in ninety (90) days was._ issued.
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. May 23, 1980 - - Licen'see response to Notice of Violation confirmed, with minor exceptions, all'of the twenty-two l
(22) items of noncompliance and forwarded payment of
$100,000 civil penalty.
July 17, 1980
.NRC Immediate Action Letter noting the actions that would be'taken by the licensee for-AWS welder qualification.
July 28, 1980 - Licensee response to Order to Show Cause addressed all 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:
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.c 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
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1 nine months. These sources are as follows:
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. Three Immediate Action Letters (IALs)
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1.
2.
Special Investigation Report l
l 3.
Notice of Violation and Civil Penalty 4.
Order to Show Cause 5.
Public Meeting l6.
Written Requests from the NRC For ease of control the various requirements and commitments have been categorized into ten (10) i subject areas. This system _is being used both by the licensee and the NRC for consistency.
These categories encompass the various subjects that have been addressed throughout the period, beginning with the special investigation.
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The Commissioners.
Ew Each of the requirements or commitments is being
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placed in one of the categories creating a listing of actions to be completed.
This systematic approach will provide the NRC staff with a good mechanism for monitoring the licensee's actions to j
Jassure.all items.are being completed.
Careful formula-
)
Etion and checking of this action' control listing is.
~ 'being performed by Region IV to be~certain all necessary items are' included.
lBriefly,.Lthe'requirenehts'whichmustbemetare.
listed in general terms in the following numbered n
categories.
The detailad, specific requirements will be defined irr the NRC's action control listing.
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,zas appropriate, are being made. JExperienced management /QA consul-1
- tants are being'used.
The licensee'is to take_
actions to. revise the QA program organization based on the recommendations and the ex.nerience already gained at the South Texas Project site.
Documentation of the changes'to the-QA progr.am
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shall be made in the,PSAR-for subsequent review
- 2 by NRR.
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' 2.
.QA Program - Allegations / Harassment: An assess-ment is being made.through all levels'of the-
' - work environment.to attempt to determine:the 4
cause of the allegations and concerns of harass-ment.
A procedure to address the resolution of conflicts which may arise between personnel in production and quality disciplines is being developed-and implemented.
~ 3.. ~ QAProgram-Trending /DScumentControl:
A systematic program to assess the significance of the various nonconformances, deficiencies, deviations, changes etc.
and determine-if trends are apparent is being developed.
This program will also address the subject of document 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.
Documentation of this ph'ase of the QA Program shall be made in 4
the PSAR for subsequeni review by NRR.
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The Commissioners
- 4.
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 begin on a prescribed schedule.
The lack of a project requirement for HL&P audits on QA.
procedures-and construction procedures is being 1
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- a ': corrected in the ' program.. Implementation of:.
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'thisiphase.of. the program must.be. demonstrated.
. Documentation.shall be made in.the PSAR for i
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-l subsequent NRR review.
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Sr Q'A rogram - Personnel Qualifications: A review-3 and evaluation of QA/QC personnel qualifications are being completed and any necessary requalifi-Lcation is being performed.
Documentation shall be made in the PSAR of-the qualifications criteria for subsequent NRR review.
6.
QA Program - Welding:'A review and evaluation of previous NDE' requirements:and personnel-require-
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J ments are being completed to define past errors.
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.~and to provide input into~a corrective: program
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'which will be initiated.
Implementation of the.
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corrective action and a properly functioning.
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.,c program must be demonstrated.
Documentation shall
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'be made~in the PS4R oflthe criteria for. subsequent Y
- NRR review.
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_17.. - Construction /QC - Concrete Procedure Revisions:
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- A. review and evaluation-with necessary revisions Lto site procedures are being completed to s
incorporate controls'on. additional corrective-work in areas already accepted.
This.is also being done to incorporate a new format in proce-dures for ease cf 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 backfill and soils testing.
Any procedures found i
deficient as a result of this action are to be
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l revised.
Any safety significant deficiencies in the backfill will have to be corrected.
The Commissioners.
9.
Construction - Concrete: A review 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 defined in procedures which v.
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- " are'then toLbe; demonstrated during implementation.'
=Necessary concrete repairs are also to be made.
' 10.
Construction
. Welding:- A review and evaluation '
of records and non-destructive examinations are.
being performed on the work completed to.date in.
order-to assess the adequacy of the existing e
work.
Corrective actions as. required will be made including any necessary welding procedure changes or rework of existing welds.-
B.-
Staging / Sequence:-
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.Since logically,some corrective elements must.be icompleted before segments of the currently halted safety-related work can resume, the staff has ispecifically defined,-in a general ~ sense, 'those key ~
~ lements.
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! 1.
.The a'spects'of t'h'e QA Program Organization the Tsubject'of: current.NRC concern must be acceptable 1 l'
ito the staff.
It.is'necessary that the organiza-
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. tion be. clearly defined,' responsibilities ' clearly
'?
- delineated and authority properly vested.
Inter-
-faces between the various; organizations must be
,T clearly defined.
An assessment must.be.made by the' staff (IE & NRR) of the ability of the licensee's organization to continue to meet l
2.
'The actions necessary to correct the cause of N
the continuous and repeated allegations dealing with harassment, threats and lack of management 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 procedu'res or revisions. covering defect trends'and document control are to be issued and demonstrated by implementation using past work defects.
The staff will have to make a finding 7
with respect to the adequacy of the licensee's actions.
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- Tile Commisstoners s 4.
All new procedures or revisions addressing-the-problems found.in audits and surveillances are to be issued and demonstrated by implementation,
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~~or.shown to be ready for implementation.
The staff wil1~make an assessment of the licensee's
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3Lactions.
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-In the remaining facets-the sequence can proceed on a.
work discipline basis, but without any fixed order for the' staging of work by the licensee.. here'the level-W iof management involvement in administering the QA 7
program is broader than'that of a specific discipline, all_ requirements must.be met.-
5.-
The qualifications of pe'rsonnel involved in j
executing the QA program must have been reviewed i
and determined to meet the appropriate require-l ments.
The staff will make an assessment of the licensee's actions.
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. 6. - f. A11. necessary' revisions in the welding QA program imust have been made and verified by the staff x s, Lduring implementation.
The staff will make an p
- evaluation of the licensee'.s actions.
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- 7. -fall' concrete. construction procedures must ~ have'-
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,been revised to simplify.and clarify them for i J
' use,while retaining
- appropriate QA controls.
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' Demonstration of the implementation of these 1
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procedures must be made.
The staff will make;a-
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- l finding.on the acceptability of these procedures. 'l 8.
Nearly all soil backfill has been placed and the l
s problem is considered of less magnitude than initially concluded from the site records
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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 during the public meeting still require licensee response.
When this action is completed and a staff evaluation is completed the issue on soils and foundations will be considered completed.
9.
Certain actions defined in IALs specifically i
re, lated to concrete construction must be completed prior to the resumption of, complex concrete placements.
In addition, all known (f
defects must be located, defined and categorized
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The Commissioners 7-prior to commencing complex concrete placements lThe. defects can be addressed building by building or by working from the foundation upwards.
The staff will provide an. assessment of the 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.
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'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,
. components or structures have had these reviews completed.' The staff will provide findings
.concerning the licensee's action.
.As.various increments of work are able to proceed,;IE'
'will' issue, through Region IV, an Immediate Action.
' ' Letter, defining and~ describing the work which is s
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. authorized..'If. problems arise, an Order could be J
fis' sued to obtain the proper licensee ' actions.
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l (Ci ' Current Status:
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' Meetings have taken place, certain documents have been furnished by.-the licensee and somednspections have been performed.
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etings -
June 16, 1980 - with RIV on Order
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June 30, 1980 - with RIV on Order June 30, 1980 - with HQ on QA Organization and general assessment of NRC action July 3, 1980 - with RIV on Order N
j September 12, 1980 - with RIV on schedules and g
NRC review and closeout hp status.
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The Commissioners 8-x
. Documents -
Various 50.55(e) reports addressing findings as a result of Order and Notice of Violation.-
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-Summary of completed commitments ready for NRC,
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N, review, August 28, 1980.'
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Partial schedules for completion'of work items '
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.;s such as review of concrete placements s
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Inspections -
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June 23-26,-1980:; Soils
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July 22-24, 1980:
Soils and' Concrete items from
, the special investigation
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~ July 28-29, 1980:
Dis' position of Certain NCRs.
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g nJuly:1-31, 1980:
Resident Inspector's1 report-Wfb
- for July 1980. -
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~2-5,-1980:
- RIV Task Group inspection. '
September
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.[At the present time ' ten '(10) of the twenty-two (22)fitems 5
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,,cof noncompliance have been. closed as a result of staff-P
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'r'eview and verification of corrective steps-and results
';from the licensee's actions.. Four (4) of thirty (30).
4 unresolved items detailed in-IE Investigation Report' a _. '
No'. 50-498/79-19; 50 499/79-19 have been resolved during.
further licensee and staff actions. ~The licensee is continuing to clarify his' actions and in-some cases provide additional information as the NRC staff reviews the items.
At the-present time the staff sees no major problems in the licensee's responses which would necessitate. Commission
-action. The major element now is the time which the.
- licensee needs to complete some of the required actions.
, t.
.The licensee is continuing to pursue the reviews and linspections to which his responses committed,3and'in the near future will provide proposed schedules for resumption
- ofl 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
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programs to which the licensee committed in his written and
-oral response made during the August 19, 1980 public meeting.
The licensee on September.4, 1980 submitted preliminary information related'to the anticipated restart of safety-related welding and complex concrete' placement.- In summary
.the schedule submitted is as follows:
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' Start re-inspection and repair of' existing AWS welds
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by September 22,'1980.
Restart AWS welding (new welds)-by September ~ 22, 1980.
Start re-inspection of existing ASME welds by September 24, 1980.
Start repair of existing ASME welds by October 15, 1980.
Restart ASME welding (new welds) by October 15,-1980.
Restart complex concrete pours by October-13,' 1980.
. Based on RIV efforts to review items indicated by the
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licensee as being ready for NRC review / verification
. and the schedule submitted, a meeting was held in RIV.
on September 12,~ 1980. As a resultiof that meeting the e
_ staff -is of the opinion that the above scheduled dates
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I will slip-at least three (3) weeks. -This would niove the first actions to begin about October 15, 1980.
.D.
Resources:
An estimate of 550 inspector-hours will be required to review and evaluate corrective action pertaining to QA/QC 1
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 work associated with resumption of AWS and ASME welding of Class I structures and piping, and placement of complex concrete.
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- 3;.<.. s The Commissioners '
Coordination:
This paper has been concurred in by the Offices of Nuclear Reactor Regulation; the Executive Legal Director has no legal objection.
Victor Stello, Jr.
Director
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