ML20126H413
| ML20126H413 | |
| Person / Time | |
|---|---|
| Site: | 05000000, South Texas |
| Issue date: | 07/09/1980 |
| From: | Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML17198A238 | List:
|
| References | |
| FOIA-84-393 NUDOCS 8506100329 | |
| Download: ML20126H413 (3) | |
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ARLINGTC'N, TEXAS 76012 s~.,j July 9, 1980 Docket No. 50-498 50-499 MEMORANDUM FOR: File wu.f.W.C.Seidle, Chief,RC&ESBranch THRU:
gue* W. A. Crossman, Chief, Projects Section FROM:
W. G. Hubacek, Reactor Inspector, Projects Section
SUBJECT:
TECHNICAL MEETING WITH HOUSTON LIGHTING AND POWER COMPANY, BROWN.AND ROOT, AND CONSULTANTS REGARDING SHOW CAUSE ORDER, ITEM NO. 1 - SOUTH TEXAS PROJECT, UNITS 1 & 2, DN 50-498; 50-499 At the request of Houston Lighting and Power Company, a meeting was held in the Region IV office on July 3,1980, with the following attendees:
Houston Lightino and Power Company'(HL&P)
G. W. Oprea, Jr., Executive NG President R. A. Frazar, Manager, STP Quality Assurance Brown and Root (B&R)
K. M. Broom, Senior Vice Pres.ident Bechtel J. M. Amaral, Manager, Quality Assurance Management Analysis Company (MAC)
J. P. Jackson, Senior Vice President L. E. Zwissler, Vice President Nuclear Regulatory Coninission W. C. Seidle, Chief, RC&ES Branch W. A. Crossman, Chief, Projects Section H. S. Phillips, Resident Reactor Inspector, STP D. F. Fox, VIB Principal Inspector W. G. Hubacek, Reactor Inspector
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File - DN 50-498; 50-499 July 9, 1980 The licensee and contractor representatives presented their approach to resolution of Show Cause Item No.1 related to the licensee's Que.lity Assurance program for the South Texas Project (STP) which is sumarized as follows:
As a result of review of their QA program by their consultants (Bechtel and MAC), HL&P has chosen to implement an ASME "N" stamp type of QA organization'for STP. The B&R organization includes a quality engineering arm, an inspection am, and an auditing arm, in addition to a services arm and a Houston QA coordination arm.
The HL&P QA organization has also been restructured similar to the "N" stamp organization and includes a discipline QA am, a quality control arm, an auditing am, and an operations am. The changes in both organ-izations are intended to overcome problems which were identified as:
1.
need to simplify procedures 2.
need to strengthen documentation and analysis of failures 3.
need to strengthen indoctrination and training 4.
need to strengthen system controls including interface and document control 5.
need to strengthen management involvement in the QA program A key aspect of the new organization is the intent to establish a strong quality engineering (QE) am which will review design requirements and establish specific inspection criteria to be used by QC inspectors to minimize conflicts between construction and QC.
It is intended that QC inspectors must follow directions provided by QE and that nonconformance reports be issued for any deviations identified by QC inspectors.
Similarly, construction engineering will provide specific directions which must be followed by construction superintendents.
The organizational structure for NDE has not been defined.
Changes in staffing of the licensee's and B&R's organizations have been made resulting in numerous personnel reassignments. The most significant of these are the assignment of the HL&P Executive Vice President exclusively to nuclear affairs with STP managers answering directly to him, and the j
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o File - DN 50-498; 50-499 July 9,1980 relocation of the HL&P QA Manager to the site to provide program direction to the QA organization. A B&R Senior Vice President has been assigned full time to STP QA matters and is presently acting as B&R QA Manager.
Several critical organizational positions have been staffed by experienced consultant personnel until qualified personnel can be hired and trained.
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- S W. G. Hubacek, Reactor Inspector Projects Section cc:
K. V. Seyfrit, RIV H. D. Thornburg, RCI R. E. Shewmaker, RCI H. S. Phillips, RRI - STP
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July 2, 1980
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Docket No. 50 I.98 50-499 MDORANDUM FOR: File
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W. C. Seidle, Chief, RC&ES Branch FRCH:
R. E. Hall, Chief, Engineering Support Section W. A. Crossman, Chief, Projects Section
SUBJECT:
IECHNICAL EETING WITH BOUSTON LIGETING AND POWER COMPANT AND BROWN AND ROOT REGARDING SHOW CAUSE TIIMS NO. 5, 6, 7, 8 AND 9 - SOUTH TETAS PROJECT, UNITS 1 & 2, DN 50-498; 50-499 At the request of HL&P, a meeting was held in the Region IV office on June 30, 1980, with the following attendees:
Houston Lighting and Power Comeanv J. V. Briskin, Manager, STP Houston Operations R. L. U1 rey, Support QA Manager A. H. Guttaman, Attorney Brown and Root J. L. Hawks, Engineering Project Manager Nuclear Regulatorv C0amaission i
K. V. Seyfrit, Director (part time)
W. C. Saidle, Chief, RC&ES Branch (part time)
W. A. Crossman, Chief, Projects Section R. E. Hall, Chief, Engineering Support Section H. S. Phillips, STP Resident Reactor Inspector 1
This meeting was a continuation of the meeting held on June 17, 1980, during which HL&P and B&R representatives presented their approach to resolution of the Show Cause Order items.
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2-July 2, 1950 ylle - CN 50-498; 50-499 a
t Show Cause Item No. 5 - Stop Work Authority The status of revision of the HLAP and B&R site procedures related to Stop Work authority and implementation vere discussed; however, since these pro-cedures vill require revision to incorporate recently a=nounced and conten-plated organizational changes, copies are not yet available fcr review. A target date of July 14 has been established to incorporate necessary c'amges and issue the procedures.
Shou Cause Iter No. 6 - Trend Analvsis Two basic changes in NCE control vere identified: (1) routine rework procedures are to be developed which can be refereneed for disposition of ide=tified routine nonconformances; and (2) all NCRs vill be completed through disposition (no draft or uncompleted NCRs), 'and the originating inspector vill be furnished a copy of the completed NCR. To are%te nonconformances beyond the scope of the routine rework procedures, a Material Review Board vill be established to define NCR disposition. All NCRs (to be redesignated as DRs) vill have a fault code and a cause code established. These codes, along with fault codes frcut T - 4 nation-i Checklist discrepancies, vill be computer evaluated and tie results made available to the Trend analysis Group. Corrective Action Requests vill then be used to obtain generic corrective action on repetitive problems.
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Show Cause Item No. 7 - Design Change Control The yREA vill be discontinued; the design change request aspects of the yREA system vill be processed using a Design Change Request. All nonconformance aspects of the TREA system vill be processed on the DR system.
7"gfa== ring disposition of DRs will be acenenadsted with a new fornmHred system of design change control.
Show Cause Item No. 8 - Record Control Extensire revision to the procedures and practices for processing records into the records storage system were discussed. These include checklist control of data package contents, Quality Engineering review of records, and control of records in storage. The new procedures should be fully operational by September 1,1980; however, it was stated that all records already in storage would be reviewed for completeness and accuracy. A f*rm1 records audit is also planned prior to system turnover from construction to operations.
Show Cause Item No. 9 - Audits A schedule for development of new audit matrices for audits, including incor-
- poration of consultants into the audit schedule was discussed.
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l File - DN 50-498; 50-499 3-July 2, 1980 General 1.
The E&P representatives reported that commitment dates contained in their reply to enforcement items in Inspection Report No. 50-498/79-19; 50-499/79-19, Items 4 and 5 had not been met due to questions resulting from review of subcontractor generated procedures. A completion date of July 3, 1980, was agreed to by the NRC representatives.
2.
E&P requested clarification of reporting requirements of 10 CFR 50.55(e) relative to problems identified during implementation of corrective
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actions directed by the Show Cause Order. The NRC representative agreed to define a position on this matter.
3.
The attorney for E&P discussed the format to be used in response to the Show Cause Order items. A copy of the planned format is appended.
A subsequent meeting is planned in Region IV for July 3 to discuss the E&P actions relative to Show Cause Item No. 1.
R. E. Hall, Chief Engineering Support Section
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W. A. Crossman, Chief Projects Section
Attachment:
South Texas Project Format cc: w/att.
K. V. Seyfrit, RIV H. D. Thornburg, RCI R. E. Shevnaker, RCI H. S. Phillips, RRI - STP W. G. Hubacek, RIV
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l South Texas Project Format of Response to Order to Show Cause A.
Non-technical Response - a general sunmary of the issues involved and the licensee's response in non-technical terms - generally will include the following:
1.
Background.- a. description of the procedure
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in use at the time of the NRC investigation 2.
Problems with the old system - a brief discus-sion of the NRC findings expressed in the investigation report and the findings of HL&P and B&R upon review of the situation 3.
Description of specific Response to the Order -
Summary description of-new procedures, organ-izatfional changes, or other approaches to correcting the problems 4.
Explanation of how the responses described will correct the problems 5.
Schedule - description of the implementation schedule, including procedure issuance dates, training sessions, report completion and trial periods for perfecting new procedures B.
Technical Response - as. attachments to the non-technical response, each response will have one or more of l
the following, depending on the nature of the order, the
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progress toward completion on the response date, etc.
1.
Draft or Completed Procedures - in some cases the procedures will already be in use at the site, in others the procedures may still be under review'within HL&P and BER.
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Logic Diagrams - to assist in understanding the way the new procedures will work 3.
Interim Reports - results of studies completed as of the response date 4.
Detailed Procedure descriptions for more compli-j cated procedures, such as the field change system.
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The New QA Brochure (response to item 4) n
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June 24, 1980 Docket No. 50-498 50-499 MEMORANDUM FOR: File THRU:
i W. C. Seidle, Chief, RC&ES Branch
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R. E. Hall, Chief, Engineering Support Section W. A. Crossman, Chief, Projects Section
SUBJECT:
TECHNICAL MEETING WITH HOUSTON LIGHTING AND POWER CO.
AND BROWN AND ROOT REGARDING SHOW CAUSE ITEMS NO. 2,
,3 AND 10; SOUTH TEXAS PROJECT; UNITS 1 & 2 DN 50-498; 50-499 At the request of Housten Lighting and Power Company (HL&P), a meeting was held in the Region IV office on June 17, 1980, with the following attendees:
Houston Lighting and Power Company R. A. Frazar, Manager Quality Assurance J. N. Briskin, Manager, STP Houston Operations R. L. Ulrey, Support QA Manager Brown and Root J. R. Geurts, Vice President and Project General Manager J. L. Hawks, Engineer Project Manager T. J. Natarajan, Discipline Project Engineer G. R. Murphy, Discipline Assistant Project Engineer C. B. Pettersson, Discipline Assistant Project Engineer Nuclear Regulatory Coinnission f
W. C. Seidle, Chief, RC&ES Branch R. E. Hall, Chief, Engineering Support Section W. A. Crossman, Chief Projects Section i
J. I. Tapia, Reactor Inspector L. D. Gilbert, Reactor Inspector q (&? M ht)f
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File - DN 50-498; 50-499 June 24, 1980 The licensee representatives and their contractor presented the general approach
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to resolution of the items indicated below from the Show Cause Order dated April 30, 1980. The licensee has centralized coordination of responses to the items of the Show Cause Order under the direction of Mr. Briskin. Each item is i
being treated prograumnatically by a formally documented control program, referred to as Technical Reference Documents which will be available for inspection. These documents define the organization, staffing (including use of consultants), and tasks involved in solution of each item. Each task is broken down to define the approach to the solution, the utilization and involvement of consultants, the inethod of solution, and the projected output. Additionally, flow charts of the individual components of each item are depicted on schedule charts to highlight graphically the relationships between the tasks. Flow charts and Technical Reference Documents were discussed by the cognizant B&R engineer.
Consultants to be utilized were identified relative to the individual tasks. Qualification summaries of projected consultants were discussed and will be available for j
inspection.
l Show Cause Item No. 2 - Category I Structural Backfill l
The status of the test fill program and of the backfill boring program was reviewed. The involvement of the consultants in evaluating the data obtained to date, and the proposed statistical analysis of the data were discussed, utilizing the flow chart for the task.- The program for review of past records and design requirements was discussed, with emphasis on developing proof of i
the acceptability of the existing backfill material. The one remaining area of potential low compaction was discussed; however, a solution to this area was not presented.
Show Cause Item No. 3.a - Safety-Related Welding. AWS and AS)E Using the Technical Reference Document and the flow chart for this item, the B&R engineer discussed the program to review qualifications of all previous welders and NDE personnel. A selective a m ination of welds using NDE techniques i
based on the_ review of welder qualifications was discussed. A program of selective re-examination of welds to improve confidence in procedures and practices was pre:ented. # total review of weld filler materials was also described. A review
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of all prior NDE test reports for completed work will also be performed to verify weld and technique acceptability.
Show Cause Item No. 3.b - Safety-Related Concrete Structures The B&R engineer described the planned selective review of all records for thirty selected placements in the Reactor Containment Building internal structures, the MEA Buildings and the Fuel Handling Buildings. The NRC counnented that the con-tainment wall should also be included in the scope as necessary so as to have the
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same level of confidence in all structures. Visual inspection, utilizing knowl-l edgeable consultants, of the selected placements is planned.
Sonic testing core l
drilling, core breaks and petrography are also planned as necessary to explore placement interiors and to permit strength and integrity testing. A re-review of previous placement difficulties, including IE observations is also planned.
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File - DN 50-498; 50-499 June 24, 1980 The NRC advised HL&P that the acceptance of adequacy of the resolution of each item related to the Show Cause Order would be an IE Headquarters function, and that Region IV would inspect for implementation of the corrective actions. B&R asked if the scope of the item 3.a was directed at the B&R welding operations, or if it was necessary to examine all current and previous welding operations on site. Since the citations pertained to the AWS welding of supports and structures, and ASME welding of piping, it was the Region IV position that the scope was limited to the B&R welding operations (this was subsequently confirmed by R. Shewmaker).
A follow-on meeting to discuss additional Show Cause Items 5-9 resolution was tentatively scheduled for June 30, 1980.
- w R. E. Hall, Chief, Engineering Support Section C1 -
W. A. Crossman, Chief Projects Section cc:
K. V. Seyfrit, RIV H. Thornburg, RCI R. E. Shewmaker, RCI W. C. Seidle, RIV L. D. Gilbert W. G. Hubacek J. I. Tapia
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