ML20149F433

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/87-70 & 50-499/87-70

ML20149F433
Person / Time
Site:	South Texas
Issue date:	02/09/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8802170155
Download: ML20149F433 (2)

See also: IR 05000498/1987070

Text

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L FEB 9 1988

'In P.eply Refer To:

Dockets: -50-498/87-73

50-499/87-70

Houston Lighting &'Powee Company

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ATTN: - J. H. Goldberg, Group Vice

President, Nuclear

P.O.' Box 1700

Houston, Texas 77001

Gentlemen:

Thank you for your letter of' January 13, 1988,'in response to our letter

and Notice of Violation dated December 17, 1987. We have reviewed your reply

'and find it responsive.to the concerns raised.in our Notice of Violation. 'We

.will review the implementation of your corrective actions during a. future

inspection to determine that full compliance has been achieved and will be

maintained.

Sincerely.

Ori;;lnal Signed 11y,

A. B. Beacli

L. J. Callan, Director

Division of Reactor Projects

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cc:

Houston Lighting a Power Company

ATTN: ti. Wisenberg, Manager

Nuclear Licensing

P.O. Box 1700

Houston, Texas 77001

Houston Lighting & Power Company

ATTN: Gerald E. Vaughn, Vice President

Nuclear Operations

n. -P.O. Box 1700

Houston, Texas 77001

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January 13, 1988

ST-HL-AE 2445

File No.: G2.4

10CFR2.201

U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, DC 20555

South Texas Project Electric Generating Station

Units 1 and 2

Docket Nos. STN 50 498, STN 50 499

Response to Notice of Violation

?>uston Lighting & Power Company has reviewed Notice of Violation

87 ' -01 dated December 17, 1987 and submits the attached response pursuanc to

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10CFR2.201.

If you should have any questions on this matter, please contact Mr.

J. S. Phelps at (512) 972-7071.

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J. H. Goldberg

Group Vice Presi ent, Nuclear

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Attachment: Response to Notice of Violation 87-70-01

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A Subsidiary of flouston Industries incorporated

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cc:

Regional Administrator, Region IV Rufus S. Scott

-Nuclear Regulatory Commission Associate General Counsel

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611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company

Arlington, TX 76011 P. O. Box 1700

Houston, TX 77001

. N.- Prasad Kadambi, Proj ect Manager

U.S. Nuclear Regulatory Commission

7920 Norfolk Avenue

Bethesda, MD 20814

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Dan R. Carpenter

Senior Resident Inspector / Operations

c/o U.S. Nuclear Regulatory

Commission

P. O. Box 910

Bay City, TX 77414

Claude E. Johnson

Senior Resident Inspector / Construction

c/o U.S. Nuclear Regulatory

Commission

P. O. Box 910

Bay City, TX 77414

J. R. Newman, Esquire

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Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036

R. L. Range /R. P. Verret

Central Power & Light Company

P. O. Box 2121

Corpus Christi, TX 78403

R. John Miner (2 copies)

Chief Operating Officer

City of Austin Electric Utility

721 Barton Springs Road

Austin, TX 78704

R. J. Costello/M T. Hardt

City Public Service Board

P. O. Box 1771

San Antonio, TX 78296

Revised 11/20/87

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G ST-HL AE-2445

File No.: G2.4

Page 1 of 3

Response to Notice of Yiolation 87-70-01

I. Statement of Violation

An NRC Inspection conducted from October.19, 1987 to November 20, 1987,

identified a violation of NRC requirements. The violation involved a

failure to follow procedures.

" Criterion V of Appendix B to 10 CFR Part 50 requires that

activities affecting quality be prescribed by and accomplished with

appropriate instructions, procedures, or drawings. This requirement

is amplified by the approved Quality Assurance Program Description

(QAPD) of South Texas Project (STP).

Standard Site Procedure (SSP) 16, Revision 3, paragraph 4.3.3,

states that 'The craf t supervisor and/or discipline Field Engineer

shall be responsible to ensure that the latest design drawings and

amendments are used to perform work.'

Specification 3A010SS0030, Revision 9, paragraph 7.2.2.1, states

that ' Welds shall be as shown on the drawings unless otherwise

reviewed and accepted by the engineer'.

Contrary to the above, during an inspection of the Unit 2 control

room ceilir.g structural steel, a Class 9 penetration cover plate was

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welded to a Class 3 structural channel beam which was not in

accordance with design drawings and field change request (FCR)

BC-0-2780 and was not reviewed or accepted by engineering.

This is a Severity Level IV violation."

II. peason for Violation

The root causes of this deficiency have been determined to be as follows:

o Lack of attention to detail on the part of the craft foreman in

laying out the work for his crew.

o Af ter the installation was completed, the craft foreman identified '

the deviation from the design drawings and notified the Field

Engineer. The Field Engineer failed to recognize the need to

document the problem by issuing a Nonconformance Report (NCR).

III. Corrective Actions Taken and Results Achieved

A

A review of the design details for non safety related civil / structural l

attachments to Category I (Class 3) structural steel in Unit 2 was

performed. Non safety related Civil / Structural installations in

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ST-HL-AE-2445

File No.: C2.4

Page 2 of 3

Category I areas are typically limited to the following types:

o Handrail and toeplate

o Checker plate and grating including support angles

o Ladders and cages

o Stair treads

o Penetration closure plates

o Miscellaneous platforms

Except for penetration closure plates, the other types of installations

listed above have specific design authorization for attachment to

Category I steel. Typical details for installations of grating call for

attachment to Category I steel utilizing welded studs with clips.

Checker plate may be welded or bolted, depending on the specific details.

Handrail and toeplate, stair treads, miscellaneous platforms, and ladders

and cagea are detailed to be welded to Category I structural steel and/or

embeds.

Penetration closure plate details do not include provisions for

attachment to Category I structures ether than by expansion anchors to

concrete or welding to embedded angle frames.

A representative sample of non-safety-related Civil / Structural

installations in Category I areas (as described above) has been

a reinspected. No unauthorized attachments to Category I structural steel

were found. The sample was representative of all buildings in the Unit 2

power block. Special emphasis was given to penetration closure plates;

all installations with which the field engineers and ironworker foreman

were involved were identified and reinspected.

The sample consisted of over 500 individv.al attachments to Category I

structural steel in addition to the grating and checker plate. Crating

was verified to have been installed utilizin5 authorized clips.

Additionally, the underside of the grating was oxamined for unauthorized

welding to the edge of beam flanges. Gracing examined utilized

authorized clips; no unauthorized attachments were found.

Overall, the reinspection identified no unauthorizad attachments in any

of the categories listed above.

In addition to the above sample, a surveillance into the cited violation

was performed. The surveillance consisted of a review of the design

details for non safety-related Civil / Structural attachments to Category I

structures, partial reinspection of installed attachments to Category I

structural steel in accordance with design details and an interview of

structural field engineers to determine if they have any knowledge of

other unauthorized attachments. No additional unauthorized attachments

were identified.

The specific deficiency cited by the NRC inspector has been documented on

a nonconformance report and dispositioned "use as is"; the structural

adequacy of safety related steel was not affected by the attachment.

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ST-HL-AE-2445'

File No.: G2.4

Page 3 of 3

IV. Corrective Steps Taken To Avoid Further Violation

As a result of this violation, the personnel involved received immediate

reinstruction concerning attention to details on design documents and-

adherence to the design requirements. This was followed up with~a

documented reinstruction of structural-foremen / general foremen involved

in installations of this type.

Additionally, structural field engineers involved in installations of

this type have received formal reinstruction per standard site procedures

with emphasis on the need to report unauthorized attachments to Category

I structural steel.

V. Date of Full Compliance

STP is currently in full compliance,

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