ML20206P080
| ML20206P080 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/20/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206P074 | List: |
| References | |
| 50-498-85-21, 50-498-85-24, 50-498-86-12, 50-499-85-19, 50-499-85-21, 50-499-86-12, EA-86-010, EA-86-10, NUDOCS 8608270089 | |
| Download: ML20206P080 (4) | |
Text
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s NOTICE OF VIOLATION Houston Lighting & Power Company Docket Nos. 50-498 and 50-499 South Texas Project Units I and ?
License Nos. CPPR-128 and CPPR-129 EA 86-10 During NRC inspections conducted during the periods of October 21 - November 22, 1985, December 1, 1985 - January 31, 1986, and April 14 - April 18, 1986, violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1986), the violations are set forth below:
I.A.
10 CFR Part 50, Appendix B, Criterion X, as implemented by the South Texas Project Quality Assurance Plan (STP QAP), Section 10.1, requires that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with documented instructions, procedures, and drawings for accomplishing the activity.
Contrary to the above, at the time of the inspections, the licensee's inspection program failed to verify conformance to instructions, procedures, and drawings. Components and structures which had been previously inspected and accepted by the licensee's contractor Quality Control (QC) personnel and which were subsequently found by the NRC to not meet specified requirements are listed below:
1.
Deficiencies were identified with the installation of eight of ten instruments and instrument tubing supports. Examples of these deficiencies included dimensions exceeding tolerance limits on five installations, an incorrect weld configuration on a tubing support, a support installed in accordance with an incorrect drawing detail, and a support installed with a clamp missing.
(Construction Appraisal Team Potential Enforcement Action (CAT PEA) 6.a) y, 2.
Twelve of 30 socket welds in 2-inch echedule 160 piping were found to be undersized. Additional examinations of approximately 200 welds of this type found at least 15 percent of these welds to be undersized.
(CAT PEA 6.b) 3.
On six lugged wafer valves, hex-head cc.p screws had been substituted for threaded studs and nuts which were not in accordance with the applicable essential cooling water piping installation isometric drawings and related bill of material.
(CAT PEA 6.c) 4.
Eight of 12 mechanical equipment items were not constructed or other-vise installed in accordance with applicable design or specified installation requirements.
(CAT PEA 6.d as modified by Inspection Report 50-498/86-12; 50-499/86-12) l 8608270089 860820 PDR ADOCK 05000a98 G
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5.
Fourteen of 41 supperts/ restraints were found to have completed i
structural welds smaller than those specified in the design j
drawings.
(CAT PEA 6.e)
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6.
Forty-three of 68 high strength bolts for struct ral steel j
sliding connections were found to be over-tightened. QC inspections had not assured that the bolts were installed to a l
" snug tight" condition, as specified in inspection procedures, which would allow movement in the connection.
(CAT PEA 6.f)
I.B.
10 CFR Part 50, Appendix B, Criterion III, as implemented by STP QAP, Section 3, requires that design control measures provide for-verifying or, checking the adequacy of design and that design changes, including
.l field changes, be subject to design. control measures commensurate with those applied to the original design.
4 4
Contrary to the above, it was determined at the time of the inspections that design control measures had failed to verify the adequacy of i
design in that:
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l 1.
Configurstion Control Package (CCP) 0243 for modification of motor j
operated valves had been issued and reviewed by the Architect / Engineer l
for field implementation with nignificant errors in the directions f
provided.
(CAT PEA 1.a as modified by Inspection Report 50-498/86-12;
)
50-499/86-12) i 1
j 2.
The Architect / Engineer had issued and reviewed drawings for installation of annubar flow measurement devices in safety-related i.
systems that did not include vendor installation tolerances.
(CAT PEA 1.b as modified by Inspection Report 50-498/86-12; t
i 50-499/86-12) l 3.
The Architect / Engineer had issued and reviewed installation i
drawings for certain instrument and sample lines connected to
'l the Unit I reactor coolant system pressurizer ths.t did not include the Nuclear Steam System Supplier required flow restriction orifice in each of the five lines.
(Inspection Report 50-498/85-24; 50-499/85-21 as modified by Inspection Report 50-498/86-12; 50-499/86-12) l 4.
Design drawings which incorporated Field Change Requests BC-01202, l
CC-04949, and Field Change Notice BS-1-0235 had been issued and reviewed by the Architect / Engineer in a manner that differed j
from the change document (BS-1-0235) or contained drafting-errors (BC-01202 and CC-04949).
(CAT PEA 2.b as modified by i
Inspection Report 50-498/86-12; 50-499/86-12) i f
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Notice of Violation I.C.
10 CFR Part 50, Appendix D, Criterion VII, as implemented by the STP QAP, Section 7.0, requires that measures be established to nasure that purchased equipment conforms to the procurement documents and that there shall be documented objective evidence of quality of the purchased equipment.
Contrary to the above, it was determined, at the time of the inspections, for equipment accepted by the licensee that:
1.
Several motor control centers were found not to meet Bechtel purchase specification 3E179ES1054 in that terminal extensions had been installed although these had not been specified and the bolting was too short for the load side terminal extensions on the molded case circuit breakers to properly secure the extensions.
In addition, insulating barriers installed between the extenders were inadequately secured and frequently were dislodged during installation which could allow phase-to-phase short circuits.
(CAT PEA 3.a) 2.
Fourteen of the 20 pieces of mechanical equipment were found not to meet procurement documents in that the bolting was not traceable or when traceable, was not in accordance with vendor defined requirements or with Architect / Engineer specifications for the equipment.
(CAT PEA 5 as modified by Inspection Report 50-498/86-12; 50-499/86-12) 3.
Six of the eight vendor-furnished tanks and heat exchangers did not meet procurement documents in that undersized welds were found on supports and nozzles.
(CAT PEA 3.b) 4.
Four electric motors furnished by vendors.were found to be not in conformance with the procurement document (Equipment Specification 3E319ES1040) in that three motors did not have the required terminal lugs installed on electrical connections and one motor had insulation rated for a lower maximum temperature.
(CAT PEA 3.b)
Collectively, Violations 1.A, I.B. and I.C have been catagorized as a Severity Level III problem (Supplement II).
II.A.
10 CFR Part 50, Appendix B, Criterion VIII, as implemented by the STP QAP, Section 8.0, requires that measures be established for control of, materials, parts, and components to prevent the use of incorrect or defective items. The appifcable specifications for load transformers and battery racks required the use of ASTM A-307 bolting.
ASTM A-307 requires that each bolt be marked, as a~ minimum, with the manufacturer's identification.
Contrary to the above, at the time of the inspections, unidentified fasteners had been used in the field assembly of electrical equipment.
(CAT PEA 5 as modified by Inspection Report 50-498/86-12;,50-499/86-12)
Notice of Violation II.B.
10 CFR Part 50, Appendix B, Criterion XVI, as fmplemented by the STP QAP, Section 16.0, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective material and equipment, and ncncoaformances, are promptly corrected.
Contrary to these requirements, three nonconforming conditions were identified by both the NRC inspector and the licensee regarding bent instrument nozzle piping on both the Unit 1 and Unit 2 reactor coolant nystem pressurizers and five missing orifices. One to three weeks elapsed from the initial observations before issuance of a nonconformance report or the application of " hold tags" to the equipment for the noncomforming conditions. The subsequent issuance of the nonconformance _ report and the application of hold tags occurred after the NRC questioned licensee personnel regarding their progress toward resolution of the observed problem.
(Inspection Report 50-498/
85-24; 50-499/85-21)
Collectively, Violations II.A and II.B have been categorized as a Severity Level IV problem (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to subnit to this office within 30 days of the date of this Notice, a written statement or explanation, including for each alleged violation:
(1) the reason for the violation if admitted, (2) the corrective steps that 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, considerat. ion will be given to extending the response time. You may include your previous responses to these violations by reference.
Dated at Arlington, Texas, this h ay of August, 1986.
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