IR 05000498/1986002

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insps 50-498/86-02 & 50-499/86-02

ML20199J049
Person / Time
Site:	South Texas
Issue date:	06/25/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8607080106
Download: ML20199J049 (2)

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In Reply Refer To:

Dockets: 50-498/86-02 50-499/86-02 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of April 8,1986, in response to our letter and Notice of Violation dated March 28, 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,

,Orlalnat mgn ,

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

Houston Lighting & Power Company i

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ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Brian Berwick, Esquire Asst. Attorney General Environmental Protection Div.

P. O. Box 12548, Capitol Station Austin, Texas 78711 0607080106 860625 0 PDR ADOCK 0000

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Lanny Alan Sinkin Citizens Concerned About Nuclear Power, Inc.

Christic Institute 1324 North Capitol Street Washington, DC 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 Comission Washington, DC 20555 Ray Goldstein, Esquire Gray, Allison and Becker 100 Vaughn Building 807 Brazos Austin, Texas 78701 Alvin H. Gutterman Newman & Holtzinger, P.C.

1615 L St., N.W., Suite 1000 Washington, DC 20036 Texas Radiation Control Program Director bec to DMB (IE01)

bec distrib. by RIV:

RPB DRSP Resident Inspector-0PS R. D. Martin, RA Resident Inspector-CONST. *SectionChief(RPB/C)

R&SPB * MIS SYSTEM RIV File *D. Weiss,LFMB(AR-2015)

RSTS Operator R. Pirfo, ELD R. G. Taylor, RPB/C *RSB RPB/C h / RPB BBreslau:cnm i nstable JEGad do 6/s)/86 6/setB6 6h6/ 3

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The Light NE f Ilouston Lighting & Power itO. Ilox 1700 llouston, Texas 77001 (713)228-9211 April 8, 1986 ST-HL-AE-1649 File No.: G2.4 b

Mr. Robert Regional Administrator, Region IV U. S. Nuclear Regulatory Commission gl4 611 Ryan Plaza Drive. Suite 1000 y i y

Arlington, Texas 76011 .

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Reanonne to Notice of Viointion 8602-01/8602-01

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Dear Mr. Martin:

Houston Lighting and Power Company (HIAP) has reviewed Notice of Violation 50-498/8602-01, 50-499/8602-01 dated March 28, *1986 and submits the attached response pursuant to 10CFR2.201.

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

Very truly yours, ok, J. H. Goldberg Group Vice President, Nuclear

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Attachment: Response to Notice of Violation (498/499-8602-01)

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Filo No.: G2.4 Page 1 of 2 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Emanonne to Notice of Vlointion 8602-01/8602-01 I. Stata-ant of Viointion During an NRC Inspection conducted January 6 - February 14,1986, a violation of NRC requirements was identified. The violation involved the lack of qualified procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action "10CFR Part 2 Appendix C (1985), the violation is listed below:

Failure to nrovide written (natructions or nrocedures 10CFR50, Appendix B, Criterion I requires that a program for inspection of activities shall be established and executed...to verify conformances with documented instructions, procedures, and drawings for accomplishing the activity. It is further required that if mandatory inspection hold points which require witnessing or inspection...beyond which work shall not proceed are required, these shall be indicated in appropriate documents. Criterion XVI requires that conditions adverse to quality are to be promptly identified, documented, and corrected.

Revision 12 of the licensee's " Quality Assurance Program Description," (QAPD), Section 15.0, " Nonconforming Materials, Parts or Components," requires the establishment of requirements to ensure compliance with 10CFR50 Appendix B.

Contrary to the above, there are no procedures or instructions in project documents for reporting procedural violations, which include inspection hold points not verified.

This is a Severity Level V violation. (10CFR Part 2, Supplement IE)

(498/499-8602-01)

II. Engir As discussed in Part 7 of NRC Inspection Report 498/499-86-02 this violation concerns the lack of a formal procedure to be used when Quality Control (QC) inspectors identify a hold point not verified (i.e.

missed) or other procedural violation which does not affect the quality of the hardware. Existing site procedures provide direction for Quality Assurance (QA) personnel to report procedural violations.

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ST-HL-AE-1649 File No.: G2.4

,. Pcgs 2 of 2 Although not prescribed by a formal procedure, the methodology used by Ebasco QC for handling this type of deficiency called for notification to be provided to Ebasco QA for handling in accordance with QA deficiency reporting procedures. This notification was not always required to be in writing. Subsequent to notification by the NRC that a concern existed, a procedural revision was made on January 10,1986 to Standard Site Procedure SSP-8 "Nonconformance Reporting", which required QC to notify QA in writina upon identification of such findings .

Subsequent to that revision it became apparent that confusion existed over which document (nonconformance report or memorandum as required by the January 10, 1986, revision to SSP-8) to use to identify missed inspection hold points. SSP-8 was revised on February 13,1986 to clearly state that nonconformance reports (NCRs) are required for missed hold points. The procedure revision also provided additional instructions regarding procedure violations which do not affect the quality of hardware identified by Quality Control Inspectors. The additional instructions require completion of a form entitled " Notice of Procedural Violation".

III. carrective Ac tinna Taken and Resulta Achieved Corrective steps taken are addressed in the Reply section above.

IV. Corrective S tens Tak en to Avoid Further Viointions Not applicable.

V. Date When Full ca-a14mnee Vill Be Achieved The project is currently in full compliance.

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l ST-HL-AE-1649 Ilouston I.ighting & Power Company File No.: G2.4 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 Washington, DC 20555 Austin, TX 78711 N. Prasad Xadambi, 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 Cffice of the Executive Legal Director Commission U.S. Nuclear Regulatory Comunission 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 Mr. Ray Goldstein, Esquire T.V. Shockley/R.L. Range 1001 Vaughn Building Central Power & Light Ct vany 807 Brazos

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P.O. Box 2121 Austin, TX 78701 Corpus Christi, TX 78403 Citizens for Equitable Utilities. Inc.

H.L. Peterson/C. Pokorny c/o Ms. Pcggy Buchorn City of Austin Route 1, Box 1684 P.O. Box 1088 Brazoria, TX 7742 Austin, TX 78757 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 Conunittee on Reactor Safeguards U.S. Nuclear Regulatory Commission 1717 H Street Washington, DC 20555 Revised 12/2/85 L4/NRC/e