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Discusses Insp Repts 50-498/85-21,50-499/85-19,50-498/85-24, 50-499/85-21,50-498/86-12 & 50-499/86-12 on 851021-1122, 851201-860131 & 860414-18,respectively & Forwards Notice of Violation.Concerns Expressed Re Insp Deficiencies
	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: ML20206P070; ML20206P080;
References
	EA-86-010, EA-86-10, NUDOCS 8608270086
	Download: ML20206P070 (4)
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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

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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 Portions of other PEAS were also withdrawn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 Although we have withdrawn a portion of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

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8608270086 860820

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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

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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

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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 l

actions you plan to prevent recurrence. Although you have;already provided l

your preliminary response and corrective actions to the specific CAT findings as ;

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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

Regional Administrator

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Enclosure:

Notice of Violation ,

cc:

Texas Radiation Control Program Director

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DISTRIBUTION

bec w/ encl:

PDR

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CA

JMTaylor, IE

RStarostecki, IE

JAxelrad, IE

HWong, IE

RHeishman, IE ,

MPeranich, IE

JLieberman, OGC

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Enforcement Officers

RI, RII, RIII, RV

LCobb, IE -

JCrooks, AEOD

BHayes, 01

SConnelly, OIA

DNussbaumer, OSP -

IE:ES File

IE:EA File

DCS

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

GLCons ale JEGag

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irdo EHJohnson

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