ML20206P070
| ML20206P070 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/20/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20206P074 | List: |
| References | |
| EA-86-010, EA-86-10, NUDOCS 8608270086 | |
| Download: ML20206P070 (4) | |
See also: IR 05000498/1985021
Text
_.
--
.
.
-
AUG 9 01985
Docket Nos. 50-498 and 50-499
License Nos. CPPR-128 and CPPR-129
-
EA 86-10
Houston Lighting & Power Company
ATTN:
J. H. Goldberg
Group Vice President
P.O. Box 1700
Houston, Texas 77001
,
Gentlemen:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-498/85-21 AND
50-499/85-19, 50-498/85-24 AND 50-499/85-21, 50-498/86-12 AND
50-499/86-12)
This refers to the inspections at the South Texas Project (STP) near Bay City,
Texas conducted during the periods of October 21 - November 22, 1985,
December 1,1985 - January 31, 1986, and April 14 - April 18, 1986. These
inspections were primarily conducted by the IE Construction Appraisal Team
'
(CAT) with followup by Region IV personnel. A number of Potential Enforcement
Actions (PEAS)-were identified during the inspections. The findings were
discussed in an enforcement conference held on March 27, 1986, in the Region IV
office in Arlington, Texas.
Your letter of January 10, 1986, provided your initial corrective actions in
response to the CAT inspection.
In your letter of April 2, 1986, you responded
to the specifics of the CAT inspection report and requested that the NRC
reconsider certain items. In our inspection of April 14-18, 1986, documented
in Inspection Report 50-498/86-12; 50-499/86-12, we evaluated your initial
corrective actions and based on our followup inspection and on new information
provided we withdrew PEAS 4 and 7.
Portions of other PEAS were also withdrawn
or modified as described in the report. Although we have withdrawn a portion of
the CAT findings, the remaining findings involve violations which indicate that
significant weaknesses in your program existed at the tine of the CAT inspcetion.
Violation 1.A in the enclosed Notice of Violation involves several examples of
deficiencies in your contractor's inspection program and represents a significant
l
weakness in your construction quality control program. CompoMnts and structures
which had been already in?pected and accepted by quality control personnel were
found not to meet specified requirements. The nature of the deficiencies
indicates that personnel were not paying adequate attention to detail, although
there r.re also indications that they were not being provided adequate guidance
on how to perform the inspections. He understand that essentially all of the
deficient installations were accomplished by your present contractor and
inspected by the contrsctor's quality control organire. tion.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
k
i&
8608270086 860820
k
\\
ADOCK 05000498
/
o
m
.
..
-. ___ _
'
.
.
Houston Lighting & Power Company
-2-
Violation I.B in the Notice involves several examples of the failure of design
review measures to assure the adequacy of design and indicates that your
engineers were not paying sufficient attention to detail during the design /
design change process or during design reviews. The failure of these design
review measures resulted in components being installed not in accordance with
the Architect / Engineer's or vendor's instructions.
Violation I.C in the Notice involves several examples of the failure of measures
to assure that rtrehased equipment met the procurement documents. This equipment
had been inspected by the vendor, accepted by the licensee, and installed in
the plant without being identified as not meeting procurement documents until
reviewed by the NRC CAT.
Violations I.A, I.B, and I.C collectively reflect a significant breakdown in
your quality assurance program because they involve multiple examples of
deficient construction that had not been identified by your quality assurance
program and components were installed which did not meet design or vendor
requirements. In accordance with the " General Statement of Policy and Procedure
for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1986), Violations 1.A,'
I.B, and I.C described in the enclosed Notice have been categorized in the
aggregate as a Severity Level III problem. Normally, a civil penalty is
considered for a Severity Level III violation er problem. However, after
consultation with the Director, Office of Inspection and Enforcement, I have
'
decided that a civil penalty will not be proposed in this case because of your
overall good perforrance in the general area of concern for the past several
years and your prompt and extensive corrective actions once these violations
were identified. The corrective actions included: significantly increasing
Houston Lighting & Power Company's management presence on site; realigning of
contractor organizations; reassigning cf key project personnel; increasing
training of construction personnal; and improving the system for holding
supervisors responsible for work completed.
Violation II.A involves the installation of fasteners which did not have proper
markings. Although the bolting material installed may have met strength and
material requireuents, without markings or a material control program, the NRC
could not determine whether the bolting material could satisfy its intended
application. Violation II.B involves the failure to promptly issue a non-
conformance report and apply hold tags after nonconforming conditions were
identified on instrument nozzle piping. These violations involve deficiencies
!
of a less serious nature than in Violations I.A-C but are of more than minor
concern and require additional management attention. Therefore, these violations
have been categorized in the aggregate as a Severity Level IV problem.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. Although you have;already provided
your preliminary response and corrective actions to the specific CAT findings as
.
.. .
.
.
_ _ _
_
.
.
.
1
Houston Lighting & Power Company
-3-
identified in the CAT report dated February 5, 1986, you should re-evaluate your
i
response in light of the discussion presented in this letter and-the enclosed
,
Notice. Please also provide information on how you intend to verify that your
corrective actions have improved the overall effectiveness of inspections and on
how you plan to assure yourself that the inspection deficiencies identified are
not indicative of potential construction deficiencies in the as-built plants.
After reviewing your response to this Notice, including your proposed corrective
actions, the NRC will determine whether further NRC enforcement action is neces-
sory to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
Original signed by:
-
Robert D. Martin
Robert D. Martin
l
Regional Administrator
Enclosure:
,
cc:
Texas Radiation Control Program Director
i
~
.
>
!
i
!
is
%
i
.
I
.-. .-
.
. - -
. . .
- -
.. -.-.
-- ...
,
. . - . .
I
,
,
Houston Lighting & Power Company
-
DISTRIBUTION
bec w/ encl:
SECY
CA
JMTaylor, IE
RStarostecki, IE
JAxelrad, IE
HWong, IE
RHeishman, IE
MPeranich, IE
,
JLieberman, OGC
Enforcement Officers
,
RI, RII, RIII, RV
LCobb, IE
-
JCrooks, AEOD
BHayes, 01
SConnelly, OIA
DNussbaumer, OSP
-
IE:ES File
IE:EA File
RIV Distribution:
Regional Administrator, RMartin
Division Director, DRSP
Branch Chief, RPB
Section Chief, RPSC
DPowers
Inspector (2 copies)
CWisner (ltr hd)
RDoda
RIV Files
RIV:RP
C:RPB . /
D:DRSP
E0
GLCons
ale
JEGag
irdo
EHJohnson
DAPowers
N
j
& h1
6 /M
b/1,1/86
(,/y1/86
t/r[.s7h M Y
k\\q
A. ha **1 A;$
f
o
E
I
C
IE:07
h
-
Mxelrad
RStarostecki
J,
jor
INong
RMartin
JLieberman
(V3/[(/86 8/ly/86
8
86
8/g/86
8//r/86
8//T/86
% r
- .9
k.C Yt, dee
.
,,
m
-
.