ML20052G194
| ML20052G194 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/22/1982 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| SFN:-B-0250, SFN:-B-250, ST-HL-AE-821, NUDOCS 8205140393 | |
| Download: ML20052G194 (8) | |
Text
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The Light C O m p a n y n -.muem, m - i n,m m u.- m.m a mion e n April 22,1982 ST-HL-AE-821 SFN:
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Mr. John T. Collins s
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L' Regional Administrator, Region IV
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Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 h
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Arlington, Texas 76012 y
Dear Mr. Collins:
South Texas Jeg Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Program to Disposition Ouadrex Findings This letter is in response to Paragraoh (3) in your letter of February 12, 1982 that requested a description of the corrective actions for substan-tive issues raised in the Ouadrex report and to provide the rationale for eliminating any issues for which no corrective action is to be taken.
In late October,1981 HL&P requested Bechtel Power Corporation (BPC) to review the Quadrex Report and prepare an assessment of the findings. An experienced group of nine individuals was formed as a Task Force to accomplish a preliminary review. They issued a report entitled "An Assessment of the Findings in the Quadrex Corporation Report" whicn was transmitted to your office on March 15, 1982. The purpose of the report was to provide a prelim-inary assessment of the findings and to place them in perspective with regard to the management and design actions that should be taken to permit timely disposition of all the findings.
Upon receipt of the Task Force Report, HL&P reviewed and commented upon the report and a copy of those comments was distributed to your office on April 7, 1982.
Following these comments, the attached program description was finalized. The program, as described, will be the mechanism for a systematic review of the findings; for the determination of corrective actions, if any; and for setting forth the rationale for eliminating those findings for which no corrective action is required.
If HL&P comments on the Report result in changes to the Report or a supplementary letter from the Task Force, the Task Focce final assessment will be used by BPC Engineering as guidance in com-pleting the disposition of Quadrex issues.
The basic tenet of our approach is the systematic review of the engineer-ing status of the Project by the BPC engineering team for the transition program.
In the development of the work packages the cognizant system engi-neers review the applicable Quadrex findings (using the Task Force Report as guidance), identify " action items" and document their reviews in the work package reports. As a complimentary action, an interdisciplinary work package is being developed that will address the generic findings of the Quadrex 8205140393 820422
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PDR ADOCK 05000498
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Ilouston 1.ighting & l'ower Company April 22,1982 ST-HL-AE-821 SFN: B0250 Page 2-Report and specific discipline findings not assigned to work packages, and will produce a single report containing the disposition of all Quadrex find-ings, including those addressed in the discipline work packages.
The BPC Action Item List, work plans and schedules will be the means for monitoring the implementation of those actions required to complete the disposition of Quadrex findings as identified in the work package final reports.
The attached description gives the details of our program.
If there are revisions to this program we will promptly notify your office.
Very truly yours, h
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.f Exec ive Vfce President GWO/kmr Attachment
T Houston Lighting & Power Company cc:
G. W. Oprea, Jr.
April 22,1982 J. H. Goldberg ST-HL-AE-821 J. G. Dewease SFN: V-0250 J. D. Parsons Page 3 D. G. Barker C. G. Robertson R. A. Frazar J. W. Williams J. W. Briskin J. E. Geiger R. L. Ulrey S. M. Dew J. T. Collins NRC)
D. E. Sells NRC)
W. M. Hill, Jr.
NRC)
M. D. Schwarz Baker &Botts)
R. Gordon Gooch Baker &Botts)
J. R. Newman Lowenstein,Newman,Reis,&Axelrad)
STP RMS Director, Office of Inspection & Enforcement Nuclear Regulatory Comission Washington, D. C. 20555 R. L. Range /G. W. Muench Charles Bechhoefer, Esquire Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C.
20555 H. L. Peterson/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A. vonRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livennore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808, L-46 Livennore, California 94550 i
Brian E. Berwick, Esquire William S. Jordan, III l
Assistant Attorney General Hannon & Weiss for the State of Texas 1725 I Street, N. W.
P. O. Box 12548 Suite 506 Capitol Station Washington, D. C.
Lanny Sinkin Citizens for Equitable Utilities, Inc.
Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 5106 Casa Oro Route 1 Box 1684 San Antonio, Texas 78233 Brazoria Texas 77422 l
l Jay Gutierrez, Esquire l
Hearing Attorney l
Office of the Executive Legal Director U. S. Nuclear Regulatory Ccmission Washington, D. C.
20555 Revision Date 03-30-82 l
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter S
S Houston Lighting & Power S
Docket Nos. 50-498 Company, et al.,
S 50-499 S
South Texas Project S
Units 1 and 2 S
AFFIDAVIT G. W. Oprea, Jr. being duly sworn, hereby deposes and says that he is an Executive Vice President of Houston Lighting & Power Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Program to Disposition Quadrex Findings; that he is familiar with the content thereof; and that the matters set forth therein ar true and correct to the best of his knowledge and belief.
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/,W. W. Opf66 Jr (f Executive Vice President STATE OF TEXAS S
S COUNTY OF HARRIS S Subscribed andyorn to before me, a Notary Public in and for Harris County, Texas this
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day of RM
, 1982.
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M uJ I$ Olh Notary Public in and forghe State of Texas My comission expires:
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April 21, 1982 PROGRAM TO DISPOSITION QUADREX FINDINGS A preliminary assessment of the Quadrex Report findings has been completed by the Bechtel Task Force. The BPC project engineering staff will now use the categorizations and assessments of the Task Force as an input to its evaluation and disposition of each of the findings. The findings have been assigned to an appropriate work package for a system or structure depending upon the scope of that package and the nature of the finding. Those findings for which a work package is not appropriate (primarily some of the generic findings in the Quadrex Report) are to be addressed and dispositioned in an interdisciplinary work package (the "Quadrex Package").
In addition, the "Quadrex Package" will extract from the individual work packages the disposition of any Quadrex findings, so that the "Quadrex Package" will be an encompassing document. Both the individual work packages and the "Quadrex Package" will be presented to HL&P for Review / Comment. Next, BPC will address any HL&P comments thereto and incorporate their resolution into the final reports that it issues. The dispositions of findings will range from "No Further Action Required" to redesign or new calculations. The final reports will identify the actions needed or rationale for "no action". Once the actions are identified they will be tracked until completion by nomal BPC project methods. The remaining discussion provides additional information regarding this program.
I.
Work Packages A.
The transition program that is currently undemay was described in detail in the December 11, 1981 submittal to Mr. Tedesco of NRR and khsequent presentations to Region IV personnel. BPC Engineering is reviewing the existing design and assessing its adequacy with respect to application of appropriate design criteria, codes and regulatory requirements, suitability to perfom required functions, and compliance with licensing and quality requirements. Statr of present work is being analyzed to identify the need for corrective action for any identified deficiencies, to identify matters that l
require further resolution, and to detennine the work remaining to be completed.
As a first step in performing the review the total plant design has been divided into discrete groupings called " work packages" which can be effectively reviewed as individual tasks. A work package is an assemblage of documents which describes the design, scope and the extent of completion status of the engineering.
The wor'K packages are evaluated to assess the status and adequacy of the design, including its interfaces with other elements of the plant design.
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B.
Identification of Work Packages l
To detemine the general status of design and to identify the l
breakdown of work packages, BPC Engineering has reviewed the basic STP documentation. The basic documentation included:
4 April 21, 1982
. SAR with all amendments STPEGS Design Manual (Technical Reference Documents and System Design Descriptions)
STP Engineering Procedures Manual Specification and drawing logs Design drawings From this review 182 work packages have been identified to date.
These include 170 discrete work packages covering systems, structures and major components and 12 work packages covering interdisciplinary matters. Taken together the work packages address the entire plant scope. The listing has changed as the review has progressed and it became apparent that some of the packages should be combined or divided.
C.
Review of the Work Packages The process of review and evaluation will vary according to the nature of the work under review.
In general, during the transition, BPC Engineering will evaluate the design assumptions and methods of analysis; determine whether the design satisfies the applicable criteria and addresses the necessary technical requirements; review design interfaces with vendor supplied equipment and design work of other disciplines; check for proper reference to computer output; assess the adequacy of design verification; review the design drawings; and determine if specifications and drawings are up to t
date.
The result of BPC's efforts for each work package will be documented in a report to HL&P, which will present:
(1) a brief sumary of the work covered by the package; (2) the present status of engineering, design, documentation and licensing, including any applicable Ouadrex concerns; (3) any recommendations for remedial actions; (4) any unresolved items; (5) the status of deficiencies reported under 10CFR50.5S(e) or 10CFR21; (6) a sumary of work to go, plan for transfer of remaining work, and statement of work which may require other organizations' participation;
April 21, 1982
- (7) a list of related work packages; and (8) any additional references, assumptions or special conditions.
The report for each work package will be prepared in draft fonn, and presented to HL&P.
Comments generated in the review process will be resolved and incorporated, as appropriate, into the final report.
The extent to which the work by BPC Engineering may repeat previous B&R design effort will depend on the completeness and clarity of the B&R documentation. Where there is sufficient evidence of the completeness and adequacy of calculations, design verifications and other design activities that were perfomed by B&R, the previous work will be accepted.
If there are instances where that is not the case, specific aspects of the work will be identified for further engineering action as part of the post-transition activities.
In short, BPC Engineering will perfom the design reviews necessary to satisfy BPC of the adequacy of the work so that it can be relied upon for use in further design.
II. Quadrex Work Package An inter-disciplinary work package has been established to address Quadrex findings and is identified as EN-619 (Quadrex). The effort for this work package consists of (1) review of the discipline work packages to extract a summary of their evaluation of related Quadrex finding and (2) evaluation and disposition of generic and discipline Quadrex findings not addressed in discipline work packages.
The generic findings are being primarily addressed by EN-619, although some of them are also being addressed by the discipline work packages, if applicable. The discipline work package review are comprehensive and the large volume of material being reviewed is providing insight to the significance and pertinence of the findings, whether generic or discipline (which were based on a relatively small sampling). All findings are being addressed and dispositioned to assure that either required corrective action is taken or that there is adequate justification for determining that no further action is needed in the completion of the design and continuation of the Project.
Quadrex Section 4.9 issues, relating to In-Service Inspection are also being addressed by EN-619. A work package division of responsibility was made and the Disciplines are now reviewing the issues.
Although the Bechtel Task Force Report recommends "No Further Action" for the Category 7 findings, these and all other findings are being addressed by EN-619 and assigned to the work packages as appropriate. The work package reviews of the B&R turnover material and any other related infomation developed during the reviews, will provide the necessary verification of the infomation relied upon by the Task Force and the "more detailed evaluation" recomended in the report.
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April 21, 1982 4_
effort for the Category 7 findings is found to be appropriate, this will be undertaken until all findings are closed out.
III. Procedural Aspects of Program The procedural controls used in developing, reviewing and approving the work packages are the means for assuring that a disposition of each Quadrex finding is developed.
Highlights of the transition procedural requirements associated with Quadrex findings are:
A.
The Quadrex Report is used as a reference for individual discipline review checklists.
B.
Section 2.0 of each Final Report summary will be the section that is to address the Quadrex findings.
C.
Corrective actions are to be identified and will be entered on the Action Item List, project schedule or in detailed work plans.
The following related actions b.y BPC have occurred:
A.
A division of responsibility document was issued to the Engineering Group Supervisors (EGS) that assign Quadrex findings to the appropriate work package.
B.
Copies of the entire Quadrex Report and the Bechtel Task Force Report have been made_ available to the EGS.
C.
Volumes 2 and 3 of the Quadrex Report are receiving a detailed l
review and cross correlation with Volume,1 as part of the EN-619 activity.
The review by HL&P Project Engineering of the discipline work i
l packages and EN-619 will explicitly include review of the BPC assessment and reconmendations on Quadrex findings. To enable the Engineering staff to perfonn its review, copies of the Quadrex Report and Bechtel Task Force Report have been made available.
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