IR 05000498/1985015
| ML20205N541 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/18/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8605020171 | |
| Download: ML20205N541 (2) | |
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APR 181986 In Reply Refer To:
Dockets: 50-498/8515-01-50-499/8514-01
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Houston Lighting & Power Company
- ATTN: 'J. H. Goldberg, Group Vice-
' President
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0.' Box 1700 Houston, Texas -77001 1.
Gentlemen:
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' Thank you for your letter of April 8,1986, in response. to our letter and
- Notice of Violation dated March 11, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review
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the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
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Sincerely,
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Driginal Signed By U. E. Gagliardo
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J. E. Gagliardo, Chief Reactor Projects Branch
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Houston Lighting & Power Company
- ATTN:
M. Wisenberg, Manager,
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Nuclear Licensing P. O. Box 1700
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Houston, Texas 77001-c-
Brian Berwick, Esquire I.
_ Asst. Attorney General
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Environmental Protection Div.
P.- 0. Box 12548, Capitol Station
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Ray Goldstein,. Esquire-s..
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April 8, 1986 ST-HL-AE-1648 File No.: G2.4, G12.265 Mr. Robert Regional Administrator, Region IV
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U. S. Nuclear Regulatory Commission
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South Texas Project
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Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Emmeonne to Notice of Viointion 8515-01/8514-01
Dear Mr. Martin:
Houston Lighting and Power Company (HI4P) has reviewed Notice of Violation 50-498/8515-01, 50-499/8514-01 dated March 11, 1986 and submits the attached response pursuant to 10CFR2.201.
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If you have any additional questions please contact Scott M. Head at 512-972-8392.
l Very truly yours,
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J. H. Goldberg Group Vice Presideut, Nuclear KM0/ag Attachment:
Response to Notice of Violation (8515-01 and 8514-01)
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ST-HL-AE-1648
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Filo No.: C2.4, C12.265 11ouston Lighting & Power Company Page 2
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Hugh L. Thompson, Jr., Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548, capitol Station Washington, DC 20555 Austin, TI 78711 N. Prasad Kadambi, Project Manager Lanny A. Sinkin U.S. Nuclear Regulatory Commission Christic Institute 7920 Norfolk Avenue 1324 North Capitol Street Bethesda, MD 20814 Washington, DC 20002 Claude E. Johnson Dreste R. Pirfo Esquire Senior Resident Inspector /STP Hearing Attorney c/o U.S. Nuclear Regulatory Office of the Executive Legal Director Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Washington, DC 20555 Bay City. TX 77414 Charles Bechhoefer, Esquire M.D. Schwarz, Jr., Esquire Chairman, Atomic Safety &
Baker & Botts Licensing Board One Shell Plaza U.S. Nuclear Regulatory Commission Houston, TI 77002 Washington, DC 20555 J.R. Newman, Esquire Dr. James C. Lamb, III Newman & Holtsinger, P.C.
313 Woodhaven Road 1515 L Street, N.W.
Chapel Hill, NC 27514 Washington, DC 20036
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Judge Frederick J. Shon Director, Office of Inspection Atomic Safety and Licensing Board and Enforcement U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Mr. Ray Goldstein Esquire T.V. Shockley/R.L. Range 2001 Vaughn Building Central Power & Light Company 807 Brazos P.O. Box 2121 Austin, TK 78701 Corpus Christi, TX 78403 Citizens for Equitable Utilities. Inc.
H.L. Peterson/C. Pokorny c/o Ms. Peggy Buchorn City of Austin Route 1, Box 1684 P.O. Box 1088 Brazoria, TX 77422 Austin, TI 78767 Docketing & Service Section J.B. Poston/A. vonRosenberg Office of the Secretary City Public Service Board U.S. Nuclear Regulatory Commission P.O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 (3 Copies)
Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission 1717 H Street Washington, DC 20555 12/2/85 L4/NRC/d
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Attc:hment 1
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ST-HL-AE-1648 Pile No.: C2.4, C12.265 Page 1 of 3
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South Texas Project Units 1 and 2 Docket Nos. STN 50-498 STN 50-499 Rsanonne to Notice of Violation 8515-01/9514-01 I. Stata= ant of Viointion Based on the results of aa NRC inspection conducted during the period of August 1 - September 30, 1985, and in accordance with the NRC Enforcement Policy (10CFR Part 2 Appendix C), the following violation was identified:
Failure to Maintain Per-mnant Plant Eauinment Criterion XIII of Appendix B to 10 CPR Part 50 requires measures to t
be established to control handling storage... and preservation of material and equipment... to prevent damage or deterioration.
The South Texas Quality Assurance Plan, Section 13.3, requires
"... protection and control necessary to assure that the re-quisite quality of those important' parts... are preserved WPP/QCI 28.0, Revision 11. " Maintenance of Materials and
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Equipment " Section 5.2 requires maintenance instructions and requirements to be adhered unless otherwise specified by Specifi-cation SA300GS100(2) or the supplier. Construction Maintenance Instruction (CMI)-1, " Care and Maintenance of Permanent Plant Items " establishes the Permanent Plant Maintenance (PPM) and Maintenance Action Card (MAC) systems to insure equipment is pro-tected and proper maintenance is performed.
Contrary to the above, a 100Z verification of the status of equipment gressing, a required PPM activity, revealed that 99 out of
234 pieces of safety-related equipment, approximately 42Z, had maintenance discrepancies identified from the grease verification program.
II. EaglI.
l In June of 1985, Startup personnel performing mairtanance on turned over i
equipment discovered that the bearings of Service Air Compressors No.11 and 12 (nonsafety-related) had not been lubricated as required. The applicable Maintenance Action Cards (MAC) had been signed off indicating that this equipment had been lubricated.
The NRC Resident Inspector, who was observing this activity identified this problem as Unresolved Item 85-08-01 in his exit meeting of June 28,1985, because of possible impact on afety-related equipment.
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Attcchm:nt 1 ST-HL-AE-1648 File No.: G2.4 G12.265
Page 2 of 3 A baseline inspection / verification program was then initiated to assess the implementation of lubrication requirements and to assess the safety
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significance of the deficiencies.
This verification program was completed in July,1985, and uncovered numerous maintenance discrepancies that resulted from the improper implementation of the Permanent Plant Maintenance (PPM) program.
The major areas of concern identified during the grease verification
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program were the comingling of grease and the overgressing of bearings.
Nonconformance Reports and Deficiency Evaluation Report (DER) No.85-040 were issued. The comingling of grease and overgressing was reported to the NRC persuant to 10CFR50.55(e).
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III. Corrective Actlana Tak an and Rmanita Achfavad The following actions were taken to ensure the implementation of the PPM i
program in accordance with approved site procedures.
Disassembly of safety related motors to correct overgressing and o
comingling of grease is ongoing. To date, approximately 65% of the safety-related motors for Unit I have been disassembled and identified deficiencies corrected in accordance with the STP Lubrication Problem Resolution Program. Disassembly and inspection
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of the remaining safety-related motors for Units 1 & 2 is scheduled j
to be completed by August 29, 1986.
A special training plan on " Grease Maintenance" was developed as o
part of the baseline inspection / verification program and PPM supervisors and craft personnel were trained.
A baseline inspection / verification program for lube oil, heat and o
meggering of components has also been completed. Classroom training
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sessions for craft personnel were also held for these maintenance l
attributes. In addition, the verification of acceptable positive
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purge of equipment and the equalization charge on batteries were documented through the PPM MAC system. No deficiencies of safety significance were identified. However, minor discrepancies which require further maintenance attention are being corrected in accordance with the PPM Program.
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ST-HL-AE-1648 File No.: C2.4, C12.265 Page 3 of 3
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The actions taken to correct the problems identified have been effective.
The problems identified were the result of conditions that existed prior to the Maintenance Program reorganization that occurred in March and April of 1985.
IV. Corrective Stens Which Have Been Taken to Avoid Further Violations The following corrective steps which have been taken will help to ensure the prompt resolution of problems and address the generic implications of deficiencies identified.
o Procedure CMI-1. Care and Maintenance of Permanent Plant Items, has been revised to require PPM personnel to verify the presence and condition of grease and to initiate s Maintenance Discrepancy (MD)
if additional lubrication is determined to be necessary. The dis-position of the HD will specify the type of lubricant to be added.
This change in procedure will prevent comingling and overgressing.
Appropriate personnel have been reinstructed to the procedural change.
o Project has increased the availability of Bechtel Engineering support to evaluate and resolve maintenance problems.
o Project Management has stressed the need for more involvement by supervisory and management personnel to assure adequate implemen-tation of the program and prompt resolution of trouble areas.
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Date When Full Comnliance Will Be Achieved The present Permanent Plant Maintenance program is being implemented in accordance with the South Texas Project Quality Assurance Plan and applicable site procedures. EL&P is in compliance with Criterion XIII of 10CFR50, Appendix B.
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