ML20140B126
| ML20140B126 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/07/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8603210340 | |
| Download: ML20140B126 (2) | |
See also: IR 05000498/1985019
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lIn'. Reply Refer To:. ^
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. Dockets:- 50-498/85-19 .*'
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Houston Lighting & Power Company-
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J. H. Goldberg
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. Group Vice President,-Nuclear
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Ge,ntlemen:,
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[.Thank you for your letter of February 10, 1986, in response to our letter-
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and Notiice o'f Violation.(NOV) dated January 29, 1986. As a result of our
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review, we: find that additional information is needed regarding your response-
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to' Item 2 of the NOV as discussed by C. McIntyre and S. HGd of your staff and
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,our Senior Resident'. Inspector, Ci E. Johnson, on or about February 19, 1986.
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'Please provide the supplemental. infomation with'in-30 d'ys of the date of this
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Sincerely,
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Origit:c! Signed By
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J. E. Gagliardo, Chief
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Reactor Projects Branch
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Houston Lighting & Power Company
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ATTN:
M. Wisenberg, Manager,
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~ Brian Berwick, Esquire
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Lanny Alan Sinkin . .
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Citizens Concerned About.
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' Christic. Institute.
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1324 North Capitol Street.
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Charles Bechhoefer Esquire
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Frederick J.,Shon
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R. D.. Martin, RA
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Section Chief (RPB/C)
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The Light
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f Ilouston Lighting & Power 110. Ilox 1700 llouuon. Texas 77001 (713) 228-9211
February 10, 1986
ST-HL-AE-1607
File No.: G2.4
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Mr. Robert D. Martin
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Regional Administrator, Region IV
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Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76011
South Texas Project
Units 1 & 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8519-01/8517-01
Dear Mr. Martin:
Houston Lighting and Power Company (HL&P) has reviewed Notice of
Violation 50-498/8519-01, 50-499/8517-01 dated January 29, 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,
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J. H. Goldberg
Group Vice President, Nuclear
JHG/SMH/mg
Attachment: Response to Notice of Violation (8519-01 and 8517-01)
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ST-H_-AE-1607
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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 General 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 Kadambi, Project Manager
Lanny A. Sinkin
U.S. Nuclear Regulatory Commission
Christic Institute
7920 Norfolk Avenue
1324 North Capitol Street
Bethesda,>0 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
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U.S. Nuclear Regulatory Commission'
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20555
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Mr. Ray Goldstein, Esquire
T.V. Shockley/R.L. Range
1001 Vaughn Building
Central Power & Light Company
807 Brazos
P.O. Box 2121
Austin, TX 78701
Corpus Christi, TX 78403
Citizens for Equitable Utilities, Inc.
H.L. Peterson/G. Pokorny
c/o Ms. Peggy Buchorn.
City of Austin
Route 1, Box 1684
P.O. Box 1088
Brazoria, TX 77422
Austin, TX 78767
Docketing & Service Section
J.B. Poston/A. vonRosenberg
Office of the Secretary
. City Public Service Board
U.S. Nuclear Regulatory Commission
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P.O. Box 1771
Washington, DC 20555
San Antonio, TX 78296
(3 Copies)
. Advisory Committee on Reactor Safeguards
U.S. Nuclear Regulatory Commission
1717 H Street
Washington, DC 20555
Revised 12/2/85
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Attachment 1-
-ST-It.-AE-1607
-File No. G2.4'
Page-1 of 4
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South Texas Project
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Units 1 & 2
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50-498/8519-01
50-499/8517-01
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Statement of Violation
During an. MC inspection conducted on September-30 through November 22,
.1985, one violation of M C. requirements was identified. .The violation-
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involved failure to follow procedures. In accordance with the " Generic
Statement of Policy and Procedure for WC Enforcement Actions," 10 CFR '
Part 2, Appendix C (1985), the violation is listed below:
Criteria V of Appendix B to 10 CFR Part 50 recpires activities
.affecting quality be prescribed by and accomplished in accordance
with appropriate instructions, procedures,- or. drawings. .This
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requirement is' amplified by the approved QAPD (Quality Assurance
Plan Description) for South Texas _ Project.
QCP 9.1, Revision 6, paragraph 5.4.2.A.-1, states that the QC
supervisor will: assure, during final review,;that the Weld Process
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Sheets:(WPS), welder ID, and material reference number, recorded on:
the Filler Material Issue Report (FMIR) contained in the weld
package, are documented on the Process Data Checklist (PDC) or
Multiple Process Data Checklist (WDC).
Contrary to the above, the following discrepancies were noted in
par +==s EW1329tt.5003, EW111464.5001, EW1107tt.5003, EWil14H.5003,-
EW1229tt.5003,: and EW1130lt.5002 after the support packages were
transmitted to the RMS vault.
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Some FMIRs for some of the supports listed welders who appeared
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. to have performed work on the support but were not identified -
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on the WDC.
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Some FMIR ~ material reference ' numbers-(heat numbers):were not
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documented on the WDC.
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This is a severity level V~ violation (supplement IE)-(498/8519-01).
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II. Reply
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The' discrepancies noted by the:NRC in Item 1 of the Notice of Violation
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(NDV) have essentially one basic cause. Specifically, during the welding
process for supports, Quality Control Inspectors are not required to be
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present during the entire installation. Thus welder changes may not be
noted on WDC/ PDC checklist. As a result of this problem, Quality-
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Control Procedure 10.12 required that the~QC Supervisor during final
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review annotate all WDC/ PDC's with information obtained from FMIR's
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ST-HL-AE-1607
File No. G2.4
Page 2 of 4'
contained within the package. This review effort apparently was not
adequately performed in isolated cases.
In addition, the Site
Integrated Review Group (SIRG) review criteria for packages did not -
address the use of FMIR's since even though contained in-the package,
they are not considered Quality Records. The SIRG review took place
after records were submitted to RMS.
The above situation is not indicative of a hardware problem (As noted in
the NOV). The program for welder qualification at STP assures a high
level of confidence that all welders are qualified for the welding they
perform. For example, before rod is issued to a welder his
qualifications are verified to insure that the welder is qualified for
that particular welding procedure.
The corrective actions taken relative to the problems addressed above
will be described in Section III below.
Concerning Item 2 of the NOV, during the time frame when the records in
question were prepared, site procedure QCP 10.12 did not require the
listing of the Filler Material Reference Number (equivalent to heat
number) on the MPDC/ PDC's for Class II and III supports. All supports
reviewed were from the Class III Essential Cooling Water System.
Therefore, this portion of the NOV does not constitute a violation of NRC
. requirements.
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III. Corrective Actions Taken and Results Achieved
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Relative to Item l' of the NOV, the following actions are being
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undertaken.
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All MPDC/ PDC's with discrepant ~ conditions noted in the NOV,
plus those found in the related R.&P investigation (documented
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in Standard Deficiency Report 194) have been corrected.
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The generic concern about the quality of other support record
packages already reviewed by SIRG is addressed as follows:
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For Class II and III supports the Ebasco QA program
requires- an accurate transfer of all welder information
to the WDC/ PDC. However, the ASME Code only requires
that all welders be qualified for the processes involved.
As noted in II. above, the welder qualification program at
STP assures a high level of confidence that all welders
are qualified for the work they perform. Therefore, since
it can be concluded that the ASE requirements are in fact
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met, no further action will be taken relative to Class II
and III packages.
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Attachment 1
ST-HL-AE-1607
File No.~G2.4
Page 3 of'A
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.For Class I supports, the ASE Code re' quires that all welders
'be identified on the appropriate documentation (i.e., on-
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N'DC/ PDC). . Since the discrepancies noted in.the NOV and:
related H_&P investigation bring.into question the. completeness
of the. information on the W'DC/ PDC, special action must -be
taken relative to Class.ILpackages. Specifically,-for those'
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Class:I packages that contain FMIR's that were reviewed by SIRG
prior to including FMIR's in the .SIRG review criteria, a sample-
will be-taken to determine the level of confidence that
This sample and evaluation will be completed by February 14.
If problems are found, a complete review of Class I packages
will be performed. This review and any required corrections
will be completed by March 7, 1986.
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.IV., Steps Taken or To Be Taken to Avoid Further Violations
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. Standard. Site Procedure SSP-18 " General ASME III Welding Requirements",
hastbeen revised to address the discrepancies noted in this NOV. -This
procedure defines with greater clarity the responsibilities for Welding,
Construction and Quality Control personnel. Specifically, SSP-18 has
transferred the responsibility for entering Weld Filler Material
information and Welder -Identification from the FMIR's, as well'as~ Welding
Procedures / Supplements Revision.on the W'DC/ PDC, from. Quality Control to
!the Construction Foreman. The revision was implemented on December 3,
1985.
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Quality Control insures that Welders listed:on the W'DC have actually
performed welding. This is verified during in-process activities, at -
final ~ inspection by marking or stamping of the Welder.'s Symbols at or.
adjacent to the weld joint, or at final record review.
As noted_in II. above, the procedure in effect at the time the records
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cited in the NDV were generated required that'the FMIR's be in the
support package to facilitate the QC supervisor's review. As a result of
the revision to SSP-18 with its enhanced requirements for documenting and
. verifying the welder and welding'information, the FMIR is no longer
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required to be in the package.
In addition, for those packages currently in process which were required
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to contain FMIR's, the Site Integrated Review Group has been directed to
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verify that- all W'DC/ PDC's correctly reflect the information on the
FMIR's.
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Attachment 1
ST-M_-AE-1607-
File No. G2.4-
Page 4 of 4
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V. Date When Full Compliance Will Be Achieved
.From a procedural standpoint, H.&P is in full compliance at'this
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time. _.As noted above, required corrective action could continue until'
March 7 to correct deficiencies found.in Class I packages.
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