ML20140B126

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/85-19 & 50-499/85-17.Addl Info Re Response to Item 2 of Violation Requested within 30 Days of Ltr Date

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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Houston Lighting & Power Company- *

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. ATTNi . Group J. H. Goldberg

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Vice President,-Nuclear

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Ge,ntlemen:,

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t [.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-30ad'ys of the date of this

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Sincerely,

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Origit:c! Signed By

. J. E. Gagilardo

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J. E. Gagliardo, Chief

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Reactor Projects Branch -

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ATTN: M. Wisenberg, Manager, .

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~ Brian Berwick, Esquire

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'., ' Austin, Texas 78711

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Dr. James C. Lamb, III

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Resident Inspector-0PS R. D.. Martin, RA

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The Light

NE 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 l i FEB l 21986 I

Regional Administrator, Region IV '

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Nuclear Regulatory Commission fl.h/

611 Ryan Plaza Drive, Suite 1000 L

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)

Ll/NRC/nv N [/f M b[/1

[C.-033[b

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- ' - '.' ST-H_-AE-1607

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 .

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

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U.S. Nuclear Regulatory Commission

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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Ll/NRC/nv

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Attachment 1-

-ST-It.-AE-1607

-File No. G2.4'

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South Texas Project ~

Units 1 & 2 ~

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50-498/8519-01

50-499/8517-01

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.I. 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- .

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 t

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.

l .- Some FMIRs for some of the supports listed welders who appeared

. . to have performed work on the support but were not identified -

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on the WDC.

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'2 . Some FMIR ~ material reference ' numbers-(heat numbers):were not

documented on the WDC. ,

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This is a severity level V~ violation (supplement IE)-(498/8519-01).

. II. Reply

i' The' discrepancies noted by the:NRC in Item 1 of the Notice of Violation -

P (NDV) have essentially one basic cause. Specifically, during the welding

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process for supports, Quality Control Inspectors are not required to be

present during the entire installation. Thus welder changes may not be

noted on WDC/ PDC checklist. As a result of this problem, Quality- r

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F Control Procedure 10.12 required that the~QC Supervisor during final

l 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

- Relative to Item l' of the NOV, the following actions are being '

L undertaken.

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o All MPDC/ PDC's with discrepant ~ conditions noted in the NOV,

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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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0 The generic concern about the quality of other support record

packages already reviewed by SIRG is addressed as follows:

For Class II and III supports the Ebasco QA program

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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

j 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

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2.- .For Class I supports, the ASE Code re' quires that all welders

'be identified on the appropriate documentation (i.e., on-

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' >

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

accurate .information has been recorded on the M'DC and PDC.

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. ,

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.

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As noted_in II. above, the procedure in effect at the time the records

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

required to be in the package.

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In addition, for those packages currently in process which were required

to contain FMIR's, the Site Integrated Review Group has been directed to s

verify that- all W'DC/ PDC's correctly reflect the information on the

FMIR's. ,

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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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