ML19347E483
| ML19347E483 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/19/1981 |
| From: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16251A407 | List:
|
| References | |
| 50-498-81-01, 50-498-81-1, 50-499-81-01, 50-499-81-1, NUDOCS 8104270466 | |
| Download: ML19347E483 (2) | |
Text
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Apoendix A NOTICE OF VIOLATION Houston Lighting and Power Company Docket No. 50-498; 50-499 CPPR-128; 129 As a result of the inspection conducted on January 7-30, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
Failure to Follow Procedures for Storage and Maintenance of Ecuicment 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."
Brown and Root Procedure GCP-35, Revision 3, paragraph 3.2.1, dated February 21, 1980, states, in part, "The. storage areas on the job site will be designated and classified as Storage Levels A through 0 or modifications thereof.
Requirements for each storage level are outlined in Reference 1, ANSI N45.2.2, 'QA Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water Cooled Nuclear Power Plants.'"
Paragraph 3.6.4 states, in part, "The In-Place Protecticn and Maintenance Instructions section will detail how the protection requirements ~are to i
be implemented with the equipment in place.
The Storage and Maintenance Department will co-ordinate with the lead engineer to determine the sufficiency of the existing environment in meeting the specified in place protection."
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ANSI N45.2.2, paragraph 2.7.4, relative to Level "0" requirements, states, in part, "These items require protection against the elements airborne contamination and physical damage."
Contrary to the above:
l 1.
On November 19, 1980, January 21, 22, 23 and 26, 1981, the Resident l
Reactor Inspector (RRI) inspected the Reactor Pressure Vessel (RPV),
the Main Coolant Loop (MCL) piping and the MCL pump casings located in Unit 1 and determined that the NSSS equipment was not protected as required by "D" storage requirements, in that, the RPV and the
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- .p casO,gs *,,are not saaled T.o preclude airborne contamination and access to the RPV was not controlled, in that, the RRI was able to enter the RPV unchallenged and without shoe covers.
s -a, P00R BRGINAL
2.
On January 26, 1981, the RRI inspected Residual Heat Removal (RHR)
Sjs pumps lA and 18 located in Unit 1 and observed that these pumps had
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not been adequately protected from airborne contamination consisting of heavy sandblast grit and dust composed of sandblast and cement material.
3.
The RRI observed the Equipment Storage and Maintenance Instruction Cards No. M-0321-C (RPV), M-0427/M-0428 (RPV internals), H-0344-0/
0345-0 and 0346-0 (RHR pumps) did not contain adequate storage and maintenance instructions, in that, vendor and ANSI N45.2.2 require-ments for in place storage were not set forth.
Adaquate instructions were not provided relative to in place protection of the equipment when moved from warehouses where level "B" storage conditions were maintained into the construction area where level "C" or "0" storage conditions were maintained and the equipment was exposed to a harsh environment caused by sandblasting.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR Part 2.201, Houston Lighting and Power Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
In regard to item 1, the licensee subsequently sealed the areas referred to; consequently, the response to this item need only to address recurrence control.
I date:
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W. C.'Seiale, Chief Engineeking Inspection Branch l
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