ML20148G665

Notice of Violation from Insp on 880125-0212.Violation Noted:Failure to Designate Record Custodian & Properly Control Records & to Test Welding Matl for Different post-weld Heat Treatment Applications

ML20148G665
Person / Time
Site:	South Texas
Issue date:	03/18/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148G649	List: ML20148G644 ML20148G665 ML20148G687
References
50-498-88-07, 50-498-88-7, 50-499-88-07, 50-499-88-7, NUDOCS 8803290199
Download: ML20148G665 (2)

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APPENDIX A NOTICE OF VIOLATION Houston Lighting and Power Company Dockets: 50-498 South Texas Project (STP), Units 1 and 2 50-499 Operating License: NPF-71 Construction Permit: CPPR-129 During an NRC inspection conducted intermittently from January 25 through February 12, 1988, two violations of NRC requirements were identified. The violations involved failure to follow procedures for control of quality assurance records while in a temporary working file and failure to test welding material for different postweld heat treatment applicaticns. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1987), the violations are listed below:

A. Failure to Designate a Record Custodian and Properly Control Records While in a Temporary Working File 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, states, in part, ". . . . Consistent with applicable regulatory requirements, the applicant shall establish requirements cone.erning record retention, such as duration, location, and assigned responsibi;ity."

Section 6.10 "Record Retention," of the STP Technical Specifications, paragraph 6.10.2, states, in part, "The following records shall be retained for at least 5 years: . . . d. Records of surveillance activities, inspections, and calibrations required by these Technical Specifications."

STP Procedure OPGP03-ZA-0042, "Operations Quality Records," dated December 31, 1987, paragraphs 4.3.4 and 4.3.5 require designating a record custodian responsible for the control of. records while in a division quality assurance record file and establish the maximum retention time as 90 days.

Contrary to the above, on January 27, 1988, surveillance test records in the engineering department division record file were found to be lacking required record retention control. A record custodian with the responsibility for the control of records while in the division file had not been designated and procedures did not exist to control access to the division file.

This is a Severity level IV violation. (SupplementI)(498/8807-01)

B. Failure to Test Welding Materials for Different Postweld Heat Treatment Applications 10 CFR Part 50, Appendix B, Criterion IX, Control of Special Processes, states, in part, "Measures shall be established to ensure that special 8003290199 DR 880318 ADOCK 0500049s DCD

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acesses, including welding, heat treating . . . are controlled and

. :omplished in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Bechtel Specification 5A010PS002, Revision 13, requires that the penetration assembly to penetration sleeve weld shall be in accordance with ASME III, Division 1, 1974 Edition through Winter 1975 Addenda, Subsection NE or Subsection NC when criteria for welding, postweld heat treatment, or material are not provided in Subsection NE.

Paragraphs NC-2400 and NE-2400 of Subsections NC and NE require testing of all welding material used in construction and that the test coupons shall be postweld heat treated to the specified temperature indicated in the welding procedure specification.

Contrary to the above, the penetration assembly to penetration sleeve welds for the steam generator blowdown piping system were made using welding materials which had been tested after a postweld heat treatment at 1100 to 1200 F and not the 1300 to 1400'F and 1325 to 1375'F temperature ranges indicated, respectively, by the applicable Ebasco Welding Procedure Specifications WP-129 and WP-69.

This is a Severity Level IV violation. (Supplement II)(498/8807-02; 499/8807-01) l Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time, l

l DatedatAr]ington, Texas,

! this / 8TJu day of f y/0,g d; 1988.

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