IR 05000498/1986004
| ML20206T275 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/30/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8607080067 | |
| Download: ML20206T275 (2) | |
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In Reply Refer To:
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Dockets: 50-498/86-04 50-499/86-04
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Houston Lighting & Power Company ATTN:
J. H. Goldberg, Group Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:
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Thank you for your letter of May 23, 1986, in response to our letter and Notice of Violation dated May 12, 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 detennine that full compliance has been achieved and will be maintained.
Sincerely, sinal Slaned by E GAcuAnco-J. E. Gagliardo, Chief Reactor Projects Branch cc:
Houston Lighting & Power Company ATTN:
M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700
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Houston, Texas 77001 Brian Berwick, Esquire Asst. Attorney General Environmental Protection Div.
P. O. Box 12548, Capitol Station Austin, Texas 78711
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Lanny Alan Sinkin Citizens Concerned About Nuclear Power, Inc.
Christic Institute 1324 North Capitol Street Washington, DC 20002 gl f
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PDR ADOCK 05000498
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W Charles Bechhoefer, Esquire
~j Chairman, Atomic Safety & Licensing
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U.S. Nuclear Regulatory Commission Washington, DC 20555
j Dr. James C. Lamb, III 313 Woodhaven Road j
Chapel Hill, North Carolina 27514 Frederick J. Shon Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission i,
Washington, DC 20555
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Ray Goldstein, Esquire i
Gray, Allison and Becker i
100 Vaughn Building 807 Brazos
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i Alvin H. Gutterman Newman & Holtzinger, P.C.
1615 L St., N.W., Suite 1000 j
Washington, DC 20036 Texas Radiation Control Program Director
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RPB DRSP i
Resident Inspector-0PS R. D. Martin, RA
Resident Inspector-CONST.
- Section Chief (RPB/C)
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- MIS SYSTEM RIV File
- D. Weiss, LFMB (AR-2015)
RSTS Operator R. Pirfo, ELD
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R. G. Taylor, RPB/C
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The Light hhE Ih uston 1.ighting & Powei P.O. Ihm 1700 1Iouston. ~Ietn i dH)! (713) 228-9211 May 23, 1986 ST-HL-AE-1675 File No.:G2.4 g@20MM %
Mr. Robert Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 MY 2 } @
Arlington, Texas 76011 y
South Texas Project
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Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violation 8604-01
Dear Mr. Martin:
Houston Lighting & Power Company (HIAP) has reviewed Notice of Violation 8604-01 (50-498 & 499) dated May 12, 1986 and submits the attached response pursuant to 10CFR2.201.
If you should have any questions on this matter, please contact Mr. Scott Head at 512-972-8392.
Very truly yours, AEM/h J. H. Goldberg
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Group Vice President, Nuclear JHG/SMH/mg Attachment: Response to Notice of Violation 8604-01
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Attcchment
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ST-HL-AE-1675 File No.: G2.4 Page 2 of 3
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c.)
failure of Field Engineering personnel to properly generate a Field Change Request (FCR) prior to deviating from design documents or to properly generate a Non-Conformance Report
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(NCR) once a deviation occurred;
d.)
failure of QC personnel to identify areas where installations did not agree with the design documentation and criteria.
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III. Corrective Action Taken and Results Achieved
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The following corrective actions have been taken with regard to the identified discrepancies:
a.)
The reinspection program has been completed. A total of 126 cabinets were reinspected; 51 cabinets had at least one discrepancy. Coupled with the previous audit and the previous i
surveillances, a total of'169 cabinets were reinspected; 70 of which had at least one of the identified discrepancies, j
b.)
NCRs were issued which address the discrepancies including i
the discrepancy identified by the NRC. All of the welding i
discrepancies have been dispositioned, "use-as-is." " Rework" I
required by these NCRs was limited to clarifying drawings via j
the FCR and DCN process, c.)
Electrical QC Welding Inspectors were reinstructed on the following with regard to equipment installation:
1.)
assuring that all welds are in accordance with
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design requirements;
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assurin5 that the correct design drawings and addendums are used for installation inspection acceptance; 3.)
assuring that any deviation from design requirements is documented, j
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d.)
All Engineering, QC and craft personnel have been reinstructed on the requireme~nts for installation of electrical equipment,
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especially with regard to the use of a Request for Engineering Assistance (REA) and an FCR.
IV. Corrective Actions to be taken:
The corrective actions taken highlight and clarify the discrepancies encountered and should prevent recurrence of this type of problem at STP.
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Attrchment
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ST-HL-AE-1675 File No.: G2.4 Page 1 of 3
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South Texas Project Units 1 & 2 i
Docket Nos, STN 50-498, STN 50-499 i-Response to Notice of Violation 8604-01/8604-01 I. Statement of Violation Criterion X of Appendix B to 10 CFR Part 50 requires that activities affecting quality be subjected to an inspection program to verify
.conformance with the documented instructions, procedures and drawings for
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i accomplishing the activity. This requirement is amplified by the approved Quality Assurance Plan Description (QAPD) for the South Texas Proj ect.
QCP 10.15, Revision 3, paragraph 5.2.3.B states that the Quality Control
(QC) Inspector shall verify that all field welds required have been inspected and accepted by recording the completed acceptable welding inspection report number on the installation inspection package.
Contrary to the above, the weld configuration on Panel 3E241EDP001 differed from the weld configuration shown on "as built" drawing indicating that the panel installation had not been properly inspected to verify that the field welds were in accordance with instructions.
II. Description of Problem The NRC identified a case where the welding of a Class 1E electrical equipment mount to its base plate did not conform to design documentation. The welding in question had been QC inspected and approved.
Similar discrepancies had been identified (prior to the NRC inspection) by the HL&P Limited Readiness Review Team (LRR).
The LRR audit and subsequent surveillances identified other electrical
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equipment cabinet weld discrepancies in addition to the discrepancy noted
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in this Notice of Violation (NOV). As a result of the audit and the surveillances, a program was initiated to reinspect 100% of the QC
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accepted electrical equipment cabinet mounting welds on site.
These discrepancies were the subject of a report in accordance with 10CFR50.55(e) made March 12, 1986.
Evaluation has subscquently confirmed the adequacy of the as built welds and the discrepancies were determined not to meet the criteria for reportability pursuant to 10CFR50.55(e).
The root causes of these discrepancies have been determined to be a lack of proper attention to detail and incorrect interpretation of the design documentation by QC, Field Engineering, and Construction personnel as follows:
a.)
failure of Construction personnel to accomplish installation in
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accordance with existing design documents; b.)
failure of Field Engineering to correctly interpret design documents;
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ST-HL-AE-1675 File No.:G2.4 Houston Lighting & Power Company Page 2 cc:
Hugh' L. Thompson, Jr., Director '
Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney Ceneral for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station
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Washington, DC 20555 Austin, TX 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 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 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, TX 77002 Washington, DC 20555 J.R. Newman, Esquire Dr. James C. Lamb, III Newman & Holtzinger, 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 Citizens for Equitable Utilities, Inc.
T.V. Shockley/R.L. Range c/o Ms. Peggy Buchorn Central Power & Li ht Company Route 1, Box 1684
P.O. Box 2121 Brazoria,' TX 77422 Corpus Christi, TX 78403 Docketing & Service Section H.L. Peterson/G. Pokorny Office of the Secretary City of Austin U.S. Nuclear Regulatory Commission P.O. Box 1088 Washington, DC 20555 Austin, TX 78767 (3 Copies)
J.B. Poston/A. vonRosenberg Advisory Committee on Reactor Safeguards City Public Service Board U.S. Nuclear Regulatory Commission P.O. Box 1771 1717 H Street-San Antonio, TX 78296 Washington, DC 20555 L4/NRC/ff Revised 5/22/86 s'
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Attachment
ST-HL-AE-1675 I
File No.: C2.4 Page-3 of 3
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V. Date of Full Compliance Upon the completion of the reinspection program (April 30, 1986) and documentation of all the discrepancies STP was in full compliance.
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