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- 4. 1981
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K. Y. Seyfrit. Otrocter F101:
W. C. Se141e. Oilef. Eagtseertog lassecties Dream SEX 3:
3 EFT C399f75 - TJ PETITIM TO SU5 PDC C3trTHUCT:3 0F M STP. Fuc QCTWER 3. IM1. inifW M C30C1:3
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The fellertag teforeetten is erwriend in ressamme to I. J. hets* asas to Den Sells,estos Getener 25. 1981:
i kgTMagf13 The heeres Corporette ameert is a esseeltess's teammiesi verter of easten.
j As see, me resort is artteen to e asyttery style reser tese a cleosical 4
setenttftcese/aremptasertagstyle. That is, tes resort esas met team seeslestems but more y gtses flestags.
Peps 1 et the seWest report states to part. 'ite purpose et mis revier uns to assertste me eserell asseuesy ed the STP eastp.' meneer. parepress 2 m page 1 resegates tse llettettees of aselectag me stated persese stese it steses. la part. 'As esseustive teries of too easty eart seems11 sees by een BAR teameisel etsetelles ses setter feest61e ser assivets esser. Quases ses ressestos to aerefully series a ses19eg progres e eterates me IAA engt-seertag ressamme to heem untese sueleer teensey toness and prenlee areas.
1elicitly. It uns esorted test seen a semitag preye umld prerte sofft-ctest testpt regeretag saa essessey et me tossetest more ser9ssend ty een elsetpite.* The seres *te ltettly* ens *e s sened* testeste et the emnet that me perter usele est be esseeged to resett te eenslestems. De Eust 41se resagets met see a ses11ag eens not essertte me sa set esagers er flestejs teses e a teessessen seele. gte sim ear me tener-Joe ses11eg ts ese-tetely met statisties-.
1he last pereyest a sage 1 steens. te sort. *Deleertly 1t is effrielt to era generettasttees free partialer respeces a seestfle meetles. t the l
euer eens. se eneses senttag appreest esas est prerten testeettee of seem-i stelly seat areas la ao engt estge of me STP plot.' la ets pe o.
graph the report reseptses act a y the etffletty of erstes a constesta.
l tot sh me efffletty of erertes a generettaatte. Dested Dis, se report i
secess met mir *testeetteus of seenottally est armes* are prertees ay als agreesh as oly fermer rettes er EAP usele alle MAP to ensalass met seen essetteneste easty areas are lesessmeen ser er et11 to to tse if est servesnes.
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K. V. Seyfrit November 4, 1981 4
4 The NAC staff and interested intervener groups must consider the limitations of the report as well as the amas which were considered questionable.
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other words, one cannot lift parts of the mport and present them as absolute fact and reach conclusions when the report itself refuses to reach conclusions.
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Although same areas may be found deficient, nothing short of a full review by l
1 HLap and techtel can determine the validity of Quadmm's " indications of i
potentially weak areas." Until such a review produces at least preliminary i
or perhaps final conclusions, there is no basis for concluding that the fundamental design is flawed. This is not to imply that the sans deficiency i
will not be found, since no system, including the design system, is perfect.
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In fact. construction deficiencies reported to data by HLAP indicate same i
l deficiencies will be identified. HRC revious of design activities during l
the life of the project have not identified such generic problems. Therefore, I
desip sust he considered adequate until a full indepth review concludes other-j
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1 1.
What is the Staff positten en the Quadrea Report?
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The Quadru neport addmssa seg eeneerns in the arm of engina ring desip. While many of the eeneeres r to be subjective opiniens.
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the staff will review the NLap/Beekte evaluation of each finding and reach a final conclusion based en their een evaluation.
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Does the report conclude that the desty of the South Teams Project is fedamentally flamed?
I From our review of the Quadron Report, we have determined that it dess not conclude that the plant desip is fWadamentally flamed.
The findings in the report are werded such that seg of them reach conclusions based en opinie er limited observatten and scope.
I b.
Does the Staff an the basis of the report believe that the desip of STP is flamodt t
Based on detailed inspections /investication of the STP construction, the Staff does not believe that the STP desip is flamed. Although the Quadrea Report identified many areas of eeneern ise.
it does not t a basis that would lead a to believe otherw It must he l
in sind, housver, that the Ott does not review desip in detail.
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Construction inspection and enforessent are prediested en a prelisi-nery desien which when eagleted will fulft11 NRC regulatory require-monta. The Quadrea Report ne soubt will result in numerous apen items wiilch the Staff sust evaluate, but presently there is no evidense that any of these itses have a detrimental impact en the adequacy of the esisting structures.
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l K. V. Seyfrit November 4, 1981 1
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i 2.
Does Jordan (CEU) correctly charactedse the findings of the Quadmx i
Report in his pleading? Go through the pleading and each time the j
Quadrex Report is characterized states a.
Why it is inaccurate or, if accurate, the significance.
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It is the opinion of the RIV staff that although the excerpts from the report are quoted or urophrased accurately in the pleading, the characteHastion of twee quotes is not necessarily accurate.
l Page 1-1 of the mport states, " Ordinarily, it is difficult to l
drew generalizations from particular responses to specific questions.
i On the other hand, the chosen sampling approach does provide indi-cations of potentially weak areas in the engineering dosip of the i
i STp plant. Consequently, these indications am being besught to the attention of HLap so that they may inquire further into specific i
details and characteHastions regarding each issue with Brown and j
Root, Inc." Mr. Jordan has taken these " indications of potentially i
weak areas",, identified through a sampling program effort and charac-l teH and them as being factua findings and, from these, he has dran l
generalizations which, without the benefit of a technical evaluation.
may or may not be accurate.
It would be ig essible for the RIV staff
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to determine the accuracy of Mr. Jordan's findings without the benefit of such an evaluation.
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As to the sipificance of Mr. Jordan's findings it is the position of the RIV staff that, based en the Hak criteria effort descHbed in Mr. Optsa's letter to Karl Se t, dated October 16, Igel, the j
findings are insipificent for proposed sentevetion activities descHbed in Attachments A and 8 of the October 16 letter. The RIY j
staff considers Bechtel's evaluation of the Quedma Report findings 1
in question to be a very important facter in making this finding.
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It is the RIV staff's understanding that documentation of Bechtel's j
evaluation will be provided pHer to preeneding with constmetten I
i activities identified in the October 16 letter.
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b.
Why the construction proposed by HLap's letter of 10/16/81 is not affected by the Quadron findings?
l As discussed in the answer to Questian 3 belew, a review of the propened work activities reveals that any eenenivable desty inadequecies would have only a minimal impact en the project.
siptficant Hsk 4n proceedine)with the proposed work, and even In only one case (Itan F belew dess there appoor to be any in this instance, the Hsk potential appears too Iw to preclude the continuation of construction.
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K. V. Seyfrit November 4. 1981 l
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3.
Specifically, does the Staff believe that each of the construction i
activities listed in Attachment A to HLap's letter of 10/16/81 nmy i
proceed? What is the effect of uncertainties concerning the accuracy l
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.of the Quadrex Report en this answer?
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The specific activities identified in Attachment A have been categorized
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and discussed below:
a.
Site operational (caretaking) activities - Any expressed uncertain-ties in the design aspects of the facility would have ne apparent 1spect en these activities. Wert activities have been in preesss, t
I and if they were to be halted, a negative impact en the facility l
could occur. There is ne apparent nemtive safety tapact peton-l tial from continuation of these activ< ties.
Maintenance of the dematering system - Jebsite Maintenanan j
Maintenance of installed equipment - Jobsite Mstatenance i
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Asesiving/ Warehousing - Material Hand 11ag Preventive usintenance of stored equipment - Material Handling Maintain records vault and sentinue docu ent centrol i
Maintain fire protection system l
i b.
Repair and rework of previously esopleted er in-prosess work -
All work is considered reversible. Any empressed uncertainty i
from the Quadrea Report would have no i beyond the possible impact upon all previously ocupleted in the same area.
1 Aspair and rowert only brings the work activities into confersk l
l anon with currently estabitshed requirements.
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Reserk of Q Class items - Fabricatten Shep Applying of coatings in all areas Continue romerk and repair of A M /45 welding - FHB Unit I Rework and repair AM and AWB welds - Rt3 Unit 1 Continue repair and installation of ECW alumine bronse piping including Area O plus W. - 30p nework and repair of AN/AW5 welding - PEAR Unit 1
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K. V. Seyfrit November 4. 1981 c.
Cagletion of work activities in process and so close to cooletion as to make coupletion immaterial to the overall condition - Expressed uncertainties from the Quadrex Report would not affect the remainder of the work. Even if there'were determined to be corrective redesign, completion of the moeining work would not significantly impact on the defined rework.
Continue containment done concrete to cumpletion - RCB Unit 1 Install Diesel Generator sole plates - DGB Unit 1 d.
Continuation of work activities previously approved by NRC. or never stopped, which have well established and tuplemented procedures -
Any uncertainties expressed in the Quadrwx Report concerning design adequacy would conceivably only have a remote impact. All work activ-ities an either reversible, or repair / modification methods am medfly available.
Concre'to batching for approved structures - Concmte. Production Fabrication of conduit and cable try supports - Fabrication Shop Continuation of operations for reef concrete placements -
FM Unit 1 Continue concrete placements - 05 Unit 1 Continue installation of cable tray supports - IEAR Unit 1 Continue installation of conduit and supports - IEAR Unit 1 Continue installation of structural steel - LEAR Unit 1 Continue installation of permanent lighting - MEAR Unit 1 New work for which B&R did not do desijn work and for whid work e.
practions am well kneun based on simi er desIjus by Westinghouse -
The Quadrea Report recemosadations am not app isable to this work.
Continue reacter coolant leap welding - RCB unit 1 f.
New work, not normally reversible, for which equivalent wort has been coupleted for Unit 1 - Arw potential rework required because of inadeguacies referred to in the Quadron Aspert would only M
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- e re:actic:c c's;ecizi stfils, e.g., ~>it# fed weizers ad weid SEC ine CDerTZrt.
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'at.r: erthurias were same tv tae Staff = ass =m tae v::rt W 1
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Cc Cct:De-II,1551, tae Iagiz IT s+.4f set wit: i n, w a.!ves ="
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tracsittan fr:st 3r:se: and Rect is ':+ v.ci.
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. - i.ix. trice e' selecac sita vert at:-ing :::e :: acsitim was ch-sw -
7 As a res;;:1: ef :=is cis :xssist,3G is ::neir ie:::n cf emI, 1551, WM selec::ed wort n=fr!:fes i Sc:2 tne sa'ety-reiz:ad and m:rs.r'ety-reiz:ac arses. Failari:s recci,-t c' =is ce:cesai, =e i
regi: mal staff erthr:md ea= ;e:cese: weer acirity. Tae erahatiz ef tae safed=ela:md meet is s::mune-1::nd i: carse sca 3 acewe. kei-ticeally,1: was =cfirmed *r: One lis: c' wmi"ety eir:ad werr cid
- ne irr:ive acy safety-ceI2:ad ac:tvities.
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was N ::7 Ee au w-fer :::e :rae:giz IT ::br: ::ne aescrimed weet a=irities be
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j This er112:5z was ;c IM, acid tne ce:isim := resume =e-zim =m-Rusca actrities is w d :y :::e f:li:wim; ;ast.s: 4::fr!:ies
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S il:w!:s issuance of tae Q:;mersr Iecert, sele od====w-s c' :se a.
c re;1:sai s.aff reviamed ::ne is
., ircI-xis; 0 J. Beie, ccief, ime:::or Systens See:iac. Tencer tee + Jim Bras:2, and 5. E.
P:llif;s, Si? ;esider: Tee==r I.s ec=r. Based z :nese rerfers.
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K. V. S:yfrit Havember 4, 1981 it was determined that there did not exist a need for immediate action pending HL&P/Bechtel evaluation of the conclusions and I.
recomendations of the Quadmx evaluation.
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. b.
In the past several years, NRC personnel have conducted audits of STP aesign and programatic procedures which control design. No violations have been identified which would justify stopping design or construction. work other than those resulting from the Show Cause Order.
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1 A Region IV Task Force has devoted over 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> follow-up inspec-c.
l tion relative to the licensee's implementation / corrective QA program deficiencies or weaknesses described in the NRC Show Cause Order of April 30, 1980. The follow-up inspections include indepth inspection of civil / structural and welding activities in the areas of corrective actions and. augmented inspections of implementation during mstart of concreting and welding activities.
d.
Two hundred and twenty-five of two hundmd and thirty-six licensee commitments to correct the deficiencies or improve the QA prograsi have been implemented by the licensee and have been closed by the NRC inspectors. The balance of these commitments are nearly all ready to close based on recent licensee actions.
NRC follow-up inspections indicate that the QA program has been cormeted/
improved and the safety-mlated work activity, proposed by the licensee's letter (Appendix A), would be adequately controlled.
" Original signed bys l
y4 c. saioLE" W. C. Seidle, Chief Engineering Inspection Branch cc:
J. T. Collins G. L. Madsen W. A. Crossman R. E. Hall H. S. Phillips
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