ML20077A345
| ML20077A345 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/16/1983 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20077A337 | List: |
| References | |
| ST-HL-AE-966, NUDOCS 8307220292 | |
| Download: ML20077A345 (6) | |
Text
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The Light Company ii.. isi.,,, ugiiii,,x & r.,m m n.,x im ii.,,,si,,,.wx;,s moi gim2smii June 16, 1983 ST-HL-AE-966 File Number: G2.4
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Mr. John T. Collins JUN 2 01983 l
i Regional Administrator, Region IV U. S. Nuclear Regulatory Coninission LC'j 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
Dear Mr. Collins:
SOUTH TEXAS PROJECT Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violation Pursuant to the provisions of 10CFR2.201 enclosed is Houston Lighting &
Power Company's response to the Notice of Violation 50-498/83-02, 50-499/83-02 dated May 18, 1983.
If you should have any questions regarding this matter, please contact Mr. Michael E. Powell at (713) 877-3281.
Very truly yours,
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.Ex,utivo V ce President LJK/mg Attachment 8307220292 830718 PDR ADOCK 05000498 O
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Houston Lighting & Power Company cc:
.G. W. Oprea, Jr.
ST-HL-AE-966 J. H. Goldberg File Number: G2.4 J. G. Dewease Page 2 J. D. Parsons D. G. Barker M. R. Wisenburg R. A. Frazar J. W. Williams R. J. Maroni J. E. Geiger H. A. Walker S. M. Dew J. T. Collins H. E. Schierling W. M. Hill, Jr.
M. D. Schwarz Baker &Botts)
R. Gordon Gooch (Baker &Botts)
J. R. Newman (Lowenstein, Newman, Reis, & Axelrad)
STP RMS Director, Office of Inspection & Enfcrcement Nuclear Regulatory Commission Washington, D. C. 20555 G. W. Muench/R. L. Range Charles Bechhoefer, Esquire Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C.
20555 H. L. Peterson/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Cnapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A.~ vonRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livermore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808, L-46 Livermore, California 94550 Brian E. Berwick, Esquire William S. Jordan, III Assistant Attorney General Harmon & Weiss for the State of Texas 1725 I Street, N. W.
P. O. Box 12548 Suite 506
. Capitol Station Washington, D. C.
20006 Austin,. Texas 78711 Lanny Sinkin Citizens for Equitable Utilities, Inc.
Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233 Brazoria, Texas 77422 Robert G. Perlis, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Comission Washington, D. C.
20555 Revision Date 04-29-83
r SOUTH TEXAS PROJECT RESPONSE TO NOTICE OF VIOLATION 50-498/83-02 50-499/83-02 I.
Statement of Apparent Violation 10 CFR Part 50, Appendix B, Criterion XVII states that records shall be identifiable and retrievable and that, consistent with applicable regulatory requirements,_the applicant shall establish requirements concerning record retention such as duration, location, and assigned responsibility.
Regulatory Guide 1.88 accepts ANSI N45.2.9-1974 with comments as being an adequate basis for complying with Criterion XVII.
Revision 3 of the licensee's STP " Quality Assurance Program Description" (QAPD), Section 17.0, " Quality Assurance Records", requires the establishment of requirements to ensure compliance with 10 CFR 50, Appendix B and ANSI N45.2.9.as endorsed by Regulatory Guide 1.88.
ANSI N45.2.9, Section 6.2, requires accurate retrieval of information without undue delay.
Contrary to the above, the licensee was unable to retrieve for review by the NRC inspector the following documents substantiating accomplishment of the Brown & Root (B&R) verification program for site-fabricated anchor bolts.
These documents were requested during the period of February 1-4, 1983, but were not retrieved for review by February 24, 1983.
a.
Thirty-one test data sheets documenting accomplishment of hardness tests.
b.
Records of. training of personnel performing hardness tests to verify material for site-fabricated anchor bolts.
c.
Documentation of calibration certification of hardness testers used.
d.-
Documentation of Tele-Brinell test bar hardness certification, e.
Marked-up (red-lined) drawings identifying installed locations of site-fabricated anchor bolts.
II. Reply The status of the five categories of documents not provided to the inspector by February 24, 1983 is summarized below, a.
The thirty-one test data sheets documenting accomplishment of hardness tests have been retrieved and are available for inspection at the STP site.
b.
The training records of personnel who performed hardness tests have been retrieved with the exception of records for two individuals.
Training Records for these two persons have been requested from Brown & Root.
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The procedure controlling hardness test activities (CCP-24) c.
contains no requirement for calibration records of the hardness testequipment-(Tele-Brinell). Because use of the Tele-Brinell instrument is based upon comparison of two indentations relative to each other rather than an evaluation of the diameter of the indentation itself, any error in the microscope calibration would be applicable to both of the indentations and, therefore, would not significantly affect the evaluation. Therefore, calibration records were not a requirement and were not created.
d.
Test bars are normally purchased without certification. The Brinell hardness is indicated by a number stamped on each bar by the vendor. From the standpoint of mass testing to determine the identity of two different materials, and not to determine the actual finite properties of the material, the lack of certification of the bars is not significant. Certification records were therefere not required, and were not created.
Copies of drawings showing the location of the bolts tested for the e.
out-of-tolerance thread problem are attached to the associated Non Conformance Reports (NCR). The " red-lined" drawings referred to i
were used as part of the process of determining which bolts would l
be tested, but were not necessarily used to identify the location of the bolts that were tested. These " red-lined" drawings have not been located. A review of the test data for the bolts associated with the NCR's referred to above has indicated a factor of safety of 1.5 to 2.0 based upon the tensile strength area. Because of this factor of safety, the lack of documents recording the process of Engineering's determining which anchor bolts were to be tested is not believed to be significant. Therefore, we believe it would serve no useful purpose to search further for such documentation.
However, a study is underway to evaluate the validity and resulting conclusions of the out-of-tolerance thread test program conducted by Brown & Root.
The inability to produce the five categories of records cited is a result of two factors. Some of the requested records were not created because they were not required by the testing program. The difficulties in retrieving certain test data sheets and training records directly related to record control conditions addressed by the NRC in its Order to Show Cause issued to HL&P April 30, 1980. As a result of that Order HL&P responded with a comprehensive corrective action program. Subsequently, HL&P assumed direct supervision of the records program and began to implement programmatic improvements in the STP records management system. The implementation of the programatic improvements and the backfitting of previously generated STP l
records into the current Records Management System (RMS) is being aggressively pursued by HL&P. Approximately 200 HL&P, Bechtel and Ebasco personnel are involved. We believe this level of resources is as great as can be effectively applied and that additional resources would not contribute to speeding the backfit process. However, immediate retrieval of l
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-a small number of records created prior to the transition to Bechtel/Ebasco may not always be possible until this remedial action program is completed.
The status'of our activities has been reviewed with Region IV inspectors.
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-III. Corrective Steps Which Have Been Taken And The Results Achieved
-In order to. improve the records program for the STP, HL&P has moved to
. aggressively. implement a revised Records Management System.
Important features of this system include:
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1)
HL&P is' in direct charge of its implementation.
2)- A single filing system jointly used.by HL&P, Bechtel and Ebasco is
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in use_for the entire project.
3)
.The system is computerized and documents are appropriately cross-referenced to speed retrieval time..
4)'
New records associated with on-going work are being routinely processed into the RMS.
5)' ' Records created before the transition.to Bechtel/Ebasco are being systematically backfitted into the new computerized RMS.
IV. Corrective Action Which Will Be Taken To Avoid Further Violations As records are created by on-going design and' construction they are processed into the RMS. The Backfit Program described above will be carried to' completion. Once the Backfit effort is complete STP records will be routinely retrievable in a timely manner.
To assure this,'the HL&P Quality Assurance _(QA) department will audit
. procedural compliance with the RMS program.
In addition, supplemental audits will be. conducted to assess the technical adequacy of records by the~QA department with Engineering department personnel assigned to augment the expertise of the technical audit teams. The technical assessments.are in
. addition to the on-going St.ow Cause commitment to review records in the Site Records Storage Facility for adequacy and completeness.
V. Date When Full Compliance Will Be Achieved With~ the exception of the qualification records for the two Brown & Root test personnel mentioned above, the records which were not retrieved during the inspection period and which were required records, are now available for.
review. The two missing qualification records have been requested from Brown
& Root.
For on-going design and construction activities, HL&P is currently in.
full. compliance with regulatory requirements' regarding records retention and retrieval.-.As records are generated, they are processed into the RMS and~can be routinely retrieved.
Records created b'efore the transition to Bechtel/Ebasco are being Lsystematically backfitted into the RMS. Upon completion'of this effort, HL&P will be in full compliance with regulatory requirements regarding records retrievability._ The backfit of construction installation, inspection and test records stored in the Site Records Storage Facility will be complete by the end of 1983. Historical engineering design records will-be backfitted 3
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into the RMS prior to associated system turnover. Documentation-discrepancies identified as a result of the Backfit Program or records reviews will be routinely processed and resolved prior to associated system turnover.
If such discrepancies. affect on-going construction activities (i.e., associated equipment would be made inaccessible), the documentation discrepancy.will be resolved prior to releasing the affected activity for construction.
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