IR 05000498/1986001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/86-01 & 50-499/86-01

ML20205N548
Person / Time
Site:	South Texas
Issue date:	04/21/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8605020181
Download: ML20205N548 (2)

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In Reply Refer To: 4. R 21 M 00ckett.t 5D-493/860bol E M p/869L-01

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Houstc# tfs,hting L rowea e.n.pany r

AYTN: s. H. doldh3rq , G.wg Vice Fresident P. O. i4x ING sast4n, Texas PGil

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l Gentlemen:

Thank you for your letter of April 8,1986, in response to our letter and I Notite of Violation dated March 24, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. . We will review 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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Original Signed By

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J. E. Gagliardo J. E. Gagliardo, Chief Reactor Projects Branch cc:

Houston Lighting & Power Company ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Brian Berwick, Esquire Asst. Attorney General

' Environiaental Protection Div.

P. O. Box 12548, Capitol Station Austin, Texas 78711 RIV:RPB/C[ 7R PB/C fd RPB/

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. .. i Houston Lighting & Power Company -2-Lanny Alan Sinkin Citizens Concerned About Nuclear Power, Inc.

Christic Institute 1324 North Capitol Street

..ishington, D.C.- 20002 Charles Bechhoefer, Esquire Chairman, Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. ~ James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Frederick J. Shon Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Ray Goldstein, Esquire Gray, Allison and Becker 100 Vaughn Building

'807 Brazos Austin, Texas 78701 Texas Radiation Control Program Director bec to DMB (IE01)

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• RPB DRSP

• Resident Inspector-0PS R. D. Martin, RA

• Resident Inspector-CONST. *SectionChief(RPB/C)

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• RIV File *D. Weiss, LFMB (AR-2015)

• RSTS Operator R. Pirfo, ELD

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. The Light NE f flouston Lighting & Power itO. Box 1700 flouston, Texas 77001 (713) 228-9211 April 8, 1986 ST-HL-AE-1644 File No.: G2.4 Mr. Robert Regional Administrator, Region IV

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U. S. Nuclear Regulatory Comunission 611 Ryan Plaza Drive Suite 1000 gllg Arlington, Texas 76011 , _ y

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South Texas Project '

Units 1 di 2 Docket Nos. STN 50-498, STN 50-499

Reanonne to Notice of Violation 8601-01 l

Dear Mr. Martin:

Houston Lighting and Power Company (HI4P) has reviewed Notice of

. Violation 50-498/8601-01, 50-499/8601-01 dated March 24, 1986 and submits the

, attached response pursuant to 10CFR2.201.

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l If you should have any questions regarding this matter, please contact Mr. Scott Head at (512)-972-8392.

Very truly yours,

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J. H. Goldberg Group Vice President. Nuclear JHG/CAA/ag Attachment: Response to Notice of Violation (8601-01)

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! Fils No.: C2.4 llouston Lighting & Power Company Page 2

cc:

Bugh 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 Comission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 N. Prasad Kadambi, Project Manager Lanny A. Sinkin U.S. Nuclear Regulato .* Commission Christic Institute 7920 Norfolk Avenue 13*4 North Capitol Street Bethesda, MD 20814 Washington, DC 20002 Claude E. Johnson Oreste 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 Cosmission P.O. Box 910 Washington, DC 20555 Bay City. TX 77414 r Charles Bechhoefer, Esquire M.D. Schwarz, Jr., Esquire Chairman, Atomic Safety &

Baker & Botts Licensing Board One Shell Plaza U.S. Nuclear Regulatory Commission Houston, TX 77002 Washington, DC 20555 i J.R. Newman, Esquire Dr. James C. Lamb , III i Newman & Holtsinger, P.C. 313 Woodhaven Road 1615 L Street, N.W. Chapel Hill, NC 27514 Washington, DC 20036

, 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, TX 78701

! Corpus Christi, 11 78403 Citizens for Equitable Utilities Inc. ,

H.L. Peterson/C. Pokorny c/o Ms. Peggy Buchorn City of Austin Route 1. Box 16 84 -

P.O. Box 1088 Brazoria TI 774't2 '

Austin, TX 78767 l Docketing & Service Section ,

J.B. Poston/A. vonRosenbe.rg Office of the Secretary City Public Service Board U.S. NucJear Regulatory Commission '

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P.O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 (3 Copies)

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Advisory Comunittee en Reactor Safeguards ,

U.S. Nuclear Regulatory Coscaission i 1717 H Street Washington, DC 20555 Revised 12/2/85 L4/NRC/f

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. . . Attachment 1

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ST-HL-AE-1644 File No. G2.4 Page 1 of 2

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South Texas Project Units 1 & 2 Emanonne to Notice of Viointion 8601-01 I. Statement of Viointion During an NRC inspection conducted on January 6 - February 28,1986, one violation of NRC requirements was identified. The violation involved failure to follow procedures. In accordance with the " General Statement of Policy and Procedure of NRC Enforcement Actions " 10CFR Part 2 Appendix C (1985), the violation is listed below:

Failure To Follow Proc edures Criterion V of Appendix B to CFR Part 50 requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate instructions, procedures, or drawings. This requirement is amplified by the approved QAPD (Quality Assurance Plan Description) for the South Texas Project.

Ebasco Services Inc. Quality Control Procedure QCP-9.3, Revision 2 states that when the post veld heat treatment operation has been found to be acceptable, the Quality Control (QC) Supervisor-Mechanical, or his designee, shall sign the hold point on the Process Data Checklist (PDC).

Contrary to r.he above, the QC Hold Point on the PDC for the post weld heat treatment operation (PWHT) was signed off by QC as not applicable for three welds MS 1003-FW0054, MS 1002-FW0052, and MS 2002-FU0052, requiring PWHT. Furthermore, although the PWHT for these welds had not been performed, the status of weld MS 1003-FWOO54 was listed as complete based upon the improper QC signoff.

l l This is a Severity Level IV violation (Supplement II.D) (498/8601-01

and 499/8601-01).

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, II. Rmanon For Viointion t

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l The violation occurred due to an error by the Ebasco QC inspector and l the Qus11ty Record Document reviewers.

III. feath'e Ac tions Taken and Resulta Achieved 1. To determine the scope of the problem. Ebasco Services Incorporated (ESI) performed an investigation of all of the ASME III pipe welds at STP which require PWHT.

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Att:chment 1

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ST-HL-AE-1644

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File No. C2.4 Page 2 of 2 The three (3) welds listed in the Statement of Violation were the only welds found where the PWHT was not performed and the PPC QC hold point was signed off as not applicable by an ESI QC inspector.

Two (2) of these welds (MS 1002-FWOO52 and MS 2002-FWOO52) were found to be still in process - not indicated as completed. The status of the third weld (MS 1003-FW00054) was indicated on the PDC as complete even though the weld had not received the required PWHT.

Of the three (3) responsible ESI QC inspectors, two (2) no longer work on the project. With respect to the third QC inspector, a sample review of his past performance has been evaluated and found to be acceptable. His error is considered to be an isolated occurrence, and he has been made aware of his error and of the job and procedural requirements.

Supplemental PDCs have been issued for the subject welds to ensure that PWHT is performed.

PWHT has not as yet been performed on any ASME III piping welds.

Due to the bulkiness of the equipment and excessive set up time which is required PWHT will be performed when the majority of the welds in a given area are complete and ready for PWHT. PWHT will be performed under the supervision of the Ebasco Welding Supervisor and in accordance with Standard Site Procedures (SSP-29) and Form 84.

(Form 84 defines, by piping category or by application, the applicable welding procedures to be utilized when preparing Field Weld Data Sheets and PDCs.)

2. ESI QC issued an NCR to track the completion of PWHT on MS 1003-FWOO54. This NCR further insures that the PWHT will be performed on the MS 1003-FWOO54.

3. The appropriate QC personnel have been reinstructed on the

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importance of a PinDE hold point on a PDC.

4. The Site Integrated Records Group (SIRC) has revised the Quality F.ecord Document Review Sheet to assure that PWHT is QC approved if PWHT is noted as a QC hold point. All SIRC record reviewers have been instructed on the change to the Quality Record Document Review Sheet.

IV. corrective Stens Which Will be Taken to Avoid Further Violations Although STP considers this an isolated occurrence, the reinstruction on procedural requirements and the revision of the Quality Record Document Review Sheet should preclude recurrence.

V. Date of Full Comn11mnem Reinstruction on procedural requirements, issuance of the supplemental PDCs, and revision of the Quality Record Document Review Sheet were completed by March 6,1986. STP was in full compliance with procedures at that time.

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