ML19347E485

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Responds to NRC Re Addl Info on Violations Noted in IE Insp Repts 50-498/79-13 & 50-499/79-13.Corrective Actions:Revised QA Manual to Add Paragraph Re Corporate QA Coordinator
ML19347E485
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 02/26/1980
From: Eric Turner
HOUSTON LIGHTING & POWER CO.
To: Seidle W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML16251A407 List:
References
NUDOCS 8104270471
Download: ML19347E485 (2)


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Houston. Texas 77001 ST-EL-AZ-423 l

SFN: C-0570 Mr. W. C. Seidle Reactor Construe: ion & Engineering Suppor: Branch U.S. Nuclear Regulatory Comission Office of Inspectiori and Enforcement Region IV 611 Ryan Plaza Drive, Sui:e 1000 Arlington, TX 76012

SUBJECT:

SOUTH TIIAS PROJECT ELEC*RIC GENERATING STATION RESPONSE TO NRC INSPECTION TINDINGS DCCKET NOS. 50-498/79-13 AND 50-499/79-13

Dear Mr. Seidle:

In your le::er dated January'31, 1980, you requested the following information:

(1) additional infor=ation related to items A.1 and A.2 of our previous response, (2) a description of the measures that will be taken to assure that information of the type that was later supplied relative to items A.2, B.1, and B.3 is made available to I.E. inspectors during the conduct of inspections, and (3) dates when full compliance will be achieved.

The following is offered as our revised response:

Additional Infernation on Item A.1 Paragraph 15.5 of the previous Pittsburgh-Des Moines (PDM)

Corporate Field QA Manual stated, "A transmittal letter shall be attached to each manual or =anual revision which is distributed. Recipients shall sign, date, and return the'trans= ictal letter to the Eastern Division QA Manager or his designated representative...". The PDM ::ans=ittal

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letter describes hew the recipient is to incorporate the supple =ent in:o :he controlled =anual.

Paragraph 12.7 de-fined a anual supplement as addi:icnal requirements to :he QA Manual. PDM therefore applied the same trans ittal in-strue:1on criteria to the =anual supple =ents.

The newly l

issued PDM Corporate QA Manual has been revised to add the l

s: ace =en: in paragraph 16.5, "The Corporate QA Coordina:or l

shall issue and centrol supple =ents in the sa e =anner as l

his =anual."

l 8.10 4 2 7 0 N STAEF EXHIBIT N0. 30 m-3 l

Houston tp.t:..3 & Pm Com;n.?

Mr.,.ioidio February 26, 1980 Page Ivo Additional Infornatics on Ite: A.2 3e nov ?DM Corporate QA Manual new s:stes, " Auditors shan be qualified in accordance vi.h a Corpora:e Audito Qu.11 fica:1cn Procedure prepared by the Cc porate QA Coordinator."

Measures :o be Taken to ?: ovide an Available Infor=ation to IE Inseectors.

The specific fr.ctors resulting in infornation inadvertently not provided.:o the I.E. Inspector vere:

1) The PDM personnel directly involved were not experiencedi in interfacing direc:1y with I.E. personnel.
2) PDM and EL&? personnel misunders: cod the inspector's detailed concerns.
3) At the ti=e of the NRC Inspectics on site the audi files were not current.

Brown & Roo: QA vi n be required to cause additional trai- % g to be under:aken by' subcontractor's perscnnel to ensure that an available infor=ation is provided to I.E. Inspec: ors and that si:e audit files are kept curren: at all tines. Addi:icnal

aining vin be given to 3 rove & Roo: subcon::act surveillance personnel to verify that audit files are current.

Date When Full Conoliance Will St Achieved Full ce=pliance has been achieved for all ite=s addressed in the Notice of Viola:1on. Fun ec=pliance with the addi:1cnal recurrence centrols established in this response vin be ec= plate by March 17, 1980.

Very ::uly yours,

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E. A. Turner, Vice President

?cuer Plant Cons::ue:1cn &

Technical Services FC: pv/rka i

cc: Messrs. G. W. Oprea, Jr.

M. C. Ni:cholas (CCA)

J. R. Geur:s (3&R) l R. A. Fraza W. N. ?hillips C. W. Vincen: (3&R) l D. G. Barker L. 2. W11sen STP 3MS l

M. L. 30 chel: (CPL)

G. 3. Painter l

R. L. Range (CPL)

M. 3. Schwar: (33)

J. 3. ?cs:en (C?S)

C. G. T.. rash (33) l R. C. Mecke (C?S)

E. S. Phillips l

R. L. Eancock (CCA)

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UNITED STATES NUCLEAR REGULATORY COMMISSION 3%

REGloN IV 7 ii" 611 RYAN PLAZA DRIVE, $UITE 1000

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~ v May 19, 1980 In P.eply Refer To:

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RIV Docket No. 50-498/Rpt. 80-06 50-499/Rpt. 80-06 Houston Lighting and Pcwer Company Attn: lir. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the inspection conducted by our Resident Inspector, Mr. H. S.

Phillips, during the period of April 1980, of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units 1 and 2, and to the discussion of our findings with }ir. L. D. Wilson and other members of your staff during the inspection period.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.

Within the scope of the inspection, no items of noncompliance were identified.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any infor=ation that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such infomation be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any propriet.ry information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Docu=ent Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

h 10 STAFF EXHIBIT NO. 31

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s Houston Lighting and Power Company May 19, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

.bG W.C.Seid(e) Chief Reactor Conhtruction and Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/80-06 50-499/80-06 g'=

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEh7 REGION IV Report No. 50-498/80-06; 50-499/80-06 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units I and 2 Inspection at: South Texas Project, Matagorda County, Texas Inspection conducted: April 1980 Inspector:

of//5[go H. S. Phillips, Resident Reactor Inspector Date 05[/J!80 Approved:

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W. A. Crossman, Chief, Projects Section Date Inspection Summary:

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Inspection during April 1980 (Report 50-498/80-06; 50-499/80-06)

Areas Inspected: Routine, announced inspection by the Resident Reactor Inspector (RRI) included independent inspection performed during a site tour; follow-up inspections relative to noncompliances, unresolved matters, and 10 CFR 50.55(e) Deficiency Reports; safety related piping (welding); and containment structural steel welding. The inspection involved sixty-six i

inspector-hours by one NRC inspector.

Results: No items of noncompliance or deviations were identified.

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,c, UNITED STATES f } ') c(f(,g NUCLEAR REGULATORY COMMISSION 7.$ft.;/nf REGION IV O, ? d A

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ARLINGTON, TEXAS 76012 October 16, 1979 In Reply Refer To:

RIV Docket No. 50-498/Rpt. 79-14 50-499/Rpt. 79-14 Houston Lighting and Power Co=pany Attn:

Mr. E. A. Turner, Vice President Power' Plant Construction and Technical Services Post Office Box 1700 i

Houst, Texas 77001 Centlesen:

fais refers to the investigation conducted by Messrs. W. G. Eubacek and H. S.

Phillips of our staff during the period Septe=ber 4-7 and 11-14,1979, of activities authori:cd by NRC Canstruction Per=its No. CPPR-128 and 129 for the South Tc:ss Project, Units No. -1 and 2, concernfag an allegation by a for=er South Texas Project employee.

The investigation and our findings are discussed in the enclosed investigation report.

During the investigation, it was found that certain activities under your license appear to be in nonco=pliance with Appendix 3 to 10 CFR 50 of the NRC Regulations, l

" Quality Assurance Criteria for Nuclear Power Plants." The ites of noncompliance and reference to the pertinent requirements are identified in the enclosed Ndtice of Violation.

l One new unresolved item is identified in paragraph 2.c of the enclosed report.

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This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.

Section 2.201 requires you to submit to this office, within 30 days of your receipt of this notice, a written statement or explanation in reply including: (1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further nonccmpliance; and (3) the date when full l

co=pliance will be achieved.

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During the investigation,. it was found that certain of your activities appeared to devinte from co=aitsents in the PSAR. This item and references to the specific ce=mic=ents are identified in the enclosed Notice of Deviation. In your reply, l

please include your ce=nents concerning this ites, a description of any steps l

that have been or will be taken to correct it, a description of any steps that 1

1 STAFF EXHIBIT NO. 32 4

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Houston Lighting and Pouer Co=pany 2

October 16, 1979 have been or will be takan to prevent recurrence, and the date all corrective actions or preventive measures were or vill be completed.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room. If the report contains any infor=ation that you believe to be proprietary, it is necessary that you submit a written application to this office', within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed"that the infornation is proprietar/. The application should be prepared so that any proprietary infor=ation identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Roem. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Roem.

Should you have any questions concerning this investigation, we will be pleased to discuss them with you.

Sincerely,

. C. Seidle, Chief Reactor Construction and Engineering Support 3 ranch i

Enclosures:

1.

Appendix A, Notice of Violation 2.

Appendix 3, Notice of Deviation 3.

IE Investigation Report No. 50-498/79-14 50-499/79-14

Docket No.

Sn 98/79-14 E.59/79-14 Appendix A NOTICE OF VIOLATION Based on the results of the NRC investigation conducted on September 4-7, and 11-14, 1979, it appears that certain of your activities related to the South Texas Project, Unit 2 were not conducted in full compliance with the conditions of your NRC Construction Permit No. CPPR-129 as indicated below:

Failure to Follow Procedures for Release of Stop-Work Not'ce S-14 i

Criterion V of Appendix B to 10 C1'R 50 requires that activities affecting quality shall be accomplished in accordance with instructions or procedures.

Section 15.0 of the Bro.in & Root QA Manual and QA Procedure ST-QAP-2.7 require that approval for resuming work halted by a stop-work notice shall be documented on the stop-work notice.

Contrary to the above:

On July 20, 1979, verbal instructions were given to a QC inspector to sign a concrete p:nr and to allow placement E2-M3 to begin although Stop-Work Notice S-14 applicable to the placement was in effect. Documented partial release of Stop-Work Notice S-14 was not accomplished until August 1,1979, several days after placement E2-M3 was completed.

This is an infraction.

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Docket No. 50-498/79-14 50-499/79-14 Appendix B NOTICE OF DEVIATION Based on the results of the NRC investigation conducted on September 4-7,

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and 11-14, 1979, it appears that certain of your activities related to South Texas Project, Unit I deviate from commitments made in your Preliminary Safety Analysis Report (PSAR) as indicated below:

Appendix A of the PSAR coc:mits to Regulatory Guide 1.88 which endorses ANSI N45.2.9-1974, " Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants."

Paragraph 3.2.6 of ANSI N45.2.9 requires that corrections or supplements to QA records shall include the date and identification of the person

=aking such corrections or supplements.

Contrary to the above:

An Examination Check form documenting QC inspection of concrete placements CSI-12A and CSI-13A, dated November 9,1978, contained a supplemental entry which did not include the date of entry or identification of the person making the supplemental entry.

This is a deviation.

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.

50-498/79-14; 50-499/79-14 Docket No.

50-498; 50-499 Category A2 Licensee:

Houston Lighting and Power Company Post.0ffice Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Investigation At:

South Texas Project, Matagorda County, Texas Investigation Conducted: September 4-7 and 11-14, 1979 Inspectors: Sj, PMdd-

/o/N /M W. G. Hubacek, Reactor Inspector Date Projects Section MfHf79

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H. S. Phillips, Resident Reactor Inspector Date Projects Section i

Approved:

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/Sh/7f W. A. Crossman, Chief, Projects Section Date Investigation Su= mary:

Investi2ation on September 4-7 and 11-14, 1979 (Report No 50-498/79-14; 50-499/79-14)

Ireas Investigated: Special, unannounced investigation of allegations regarding nonconforming construction practices and insufficient quality control programs for construction at the South Texas Project. The investi-gation involved eighty inspector-hours by two NRC inspectors.

Results: One item of noncompliance (failure to follow procedures for release of.Stop-Work Notice - paragraph _2.i.) a.nd one deviation (failure to include the

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