ML20149F433
| 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
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FEB
9 1988
'In P.eply Refer To:
Dockets: -50-498/87-73
50-499/87-70
Houston Lighting &'Powee Company
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
.
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
-P.O. Box 1700
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Houston, Texas
77001
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January 13, 1988
ST-HL-AE 2445
File No.: G2.4
U. S. Nuclear Regulatory Commission
Attention:
Document Control Desk
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
'
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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W k r q f $ ~ 5 pp.
A Subsidiary of flouston Industries incorporated
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Regional Administrator, Region IV
Rufus S. Scott
-Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 1000
Houston Lighting & Power Company
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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
Newman & Holtzinger, P.C.
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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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Attachment
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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
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:
Lack of attention to detail on the part of the craft foreman in
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laying out the work for his crew.
o
Af ter the installation was completed, the craft foreman identified
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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
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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
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File No.: C2.4
Page 2 of 3
Category I areas are typically limited to the following types:
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Handrail and toeplate
Checker plate and grating including support angles
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Ladders and cages
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Stair treads
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Penetration closure plates
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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
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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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