ML20209J276
| ML20209J276 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/29/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8705040253 | |
| Download: ML20209J276 (2) | |
See also: IR 05000498/1986017
Text
o s ,
N a 2 9 ID E
In Reply Refer To:
Dockets: 50-498/86-17-
50-499/86-17
Houston Lighting & Power Company _
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P. O. Box 1700
Houston Texas
77001
Gentlemen:
Thank you for your letter of January 23, 1987, in response to our letter
and Notice of Violation dated December 19, 1986. 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,
Original Signed by
J. E. GAGLIARDO
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Houston Lighting & Power Company
ATTN:
M. 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
Houston, Texas
77001
Texas Radiation Control Program Director
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. . n. . . DISTRIBUTION: bec to DMB (IE01) bec distrib. by RIV: -RPB DRSP RRI-0PS "R. D. Martin, RA 'RRI-CONST.~ Section Chief (RPB/C) R&SPB MIS System RIV File D. Weiss, RM/ALF - RSTS Operator R. Pirfo, ELD R. G. Taylor, RPB/C RSB Project Inspector .R. Hall L. Gilbert Section Chief.,(RSB/ES) ! I r ! . . - , - , . _ . - . , . , - . , _ , . - . . . . - . . , ., -- ,,._ ... - -... .e ,
- . .. . c c... p ' . . The Light c o m P u y a e. ,,e m <>s .,e s & Fe < , s v.o. ee,3700 se ,m.m.rc,,,77001 <2i3> 22s.s2ii . - _ - . . . . January 13, 1987 ST-HL-AE-1843 File No.. G2.4 10CFR2.201 1:. S. Nuclear Regulatory Commission Attention: Document Control Desk WashinSton, DC 20555 South Texas Project Units 1 & 2 Docket Nos. STN 50 498, STN 50-499 Response to Notice of Violation 8617-01 Houston Lighting & Fower Company has reviewed Notice of l.olation 8617-01 dated December 10, 1986, and submits the attached response pursuant to 10CFR2.201. If you should have any questions on this matter, please contact Mr. S. M. Head at (512) 972-8392.
, . J. H. Goldber5 Group Vice Presidt:nt, Nuclear WPE/hg Attachment: Response to Notice of Violation 8617 01 l I l kk L4/NRC/pp $%* l __
. . . . . , - . j . , Houston Lighting & Power Company ST HL-AE-1843 , File No.: C2.4 Page 2 cc: Regional Administrator, Region IV Nuclear Regulatory Commission M.B. Lee /J. E. Malaski 611 Ryan Plaza Drive, Suite 1000 City of Austin P.O. Box 1088 Arlington, TX 76011 Austin, TX 78767 N. Prasad Kadambi, Project Manager U.S. Nuclear Regulatory Commission A. vonRosenberg 7920 Norfolk Avenue City Public Service Board P.O. Box 1771 Bethesda, MD 20814 San Antonio, IX 78296 Robert L. Perch , Project Manager Brian E. Berwick, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General for 7920 Norfolk Avenue the State of Texas Bethesda, MD 20814 P.O. Box 12548, Capitol Station Austin, TX 78711 Dan R. Carpencer Senior Resident inspector / Operations Lanny A. Sinkin c/o U.S. Nuclear Regulatory Christic Institute Commission P.O. Box 910 1324 North Capitol Street Washington, D.C. 20002 Bay City, TX 77414 Claude E. Johnson Oreste R. Pirfo, Esquire Senior Resident Inspector /STP Hearin8 Attorney c/o U.S. Nuclear Re5ulatory Office of the Executive Legal Director Cobmission U.S. Nuclear Regulatory Commission
P.O. Box 910 Washi"5 ton, DC 20555 Bey City TX 77414 Citizens for Equitable Utilities, Inc. c/o Ms. Peggy Buchorn M.D. Schwarz, Jr., Esquire Route 1, Box 1684 Baker & Botts One Shell Plaza Brazoria, TX 77422 Houston, TX 77002 Advisory Committee on Reactor Safeguards J.R. Newman, Esquire U.S. Nuclear Regulatory Commission 1717 H Street Newman & Holtzinger, P.C. Washington, DC 20555 1615 L Street, N.W. Washington, DC 20036 T.V. Shockley/R. L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 Revised 1/2/87 L4/NRC/pp . . . , , - - -- , ~ - ,
. *. . s . . ,. . . j . . Attachment ST-HL-AE-1843
File No.: C2.4 Page 1 of 3 South Texas Project Units 1 & 2 Docket Nov. STN 50-498, STN 50-499 Response to Notice of Violation 8617-01 I. Statement of Violation Based on the results of an NRC inspection conducted during the period of . September 29 through October 9, 1986, a violation of NRC requirements was idsntifind The viointion involved failure tw imp 1===uL measures to prevent entrance of foreign material in piping systems. In accordance with the NRC Enforcement Policy 10CFR2, Appendix C, (1986) the following violation was identified. 10CFR50, Appendix B, Criteria V as amplified by a licensee's quality Assurance Program requires quality affecting activities to be controlled and accomplished in accordance with applicable procedures. Site administrative procedure number SSP-22, Piping System cleanliness, invokes ANSI N45.2.1, 1973 edition, and includes the fo11ovin8 requirements: special care shall be taken to prevent the entrance of items that could cause blockage (tools, regs, etc.) in piping systems; and all visible metal particles, chips, etc., shall be removed from accessible parts after cutting, prior to proceeding with erection operations. Contrary to the above, review of radiographs performed by the NRC for inspection of South Texas Unit 2 during September 29 through October 9, 1986, disclosed that the implementation of SSP 22 did not always meet the intent of ANSI N 45.2.1 in that: debris such as wire, washers and metal shavings was found to exist within piping near velds RH 2312-KB2 C and CV2082-PB2-B. This is a Severity Level IV violation. (Supplement II) (499/8617-01) II. Reason for Violation This violation involved the failure of STP to comply with pipe cleanliness requirements. Examination of NRC Radiographic Test (RT) film of two welds in Unit 2 revealed the fo11owin5: 1.) Indications of metallic debris at or near Vendor Shop Weld (SV) two (2) of spool piece 8" RH-2312 KB2-C (serial Number 28622); 2.) Indications of metallic washers and debris at or near SW-2 of spool piece 4" CV-2082 PB2-B (serial number 21004). Based upon an evaluation of the installation of the two spools in question the following causes have been determined: Lt/NRC/pp ... . -. -. ... . --
.. *. . . ..
I ' . , . , Attachment ST HL-AE-1843 File No.: G2.4 Page 2 of 3 a.) inadequate craf t supervision of construction activities involved with piping construction and valve fit-up. It is apparent that counterboring in the vertical le5 above the 8"RH 2312-KB2-C spool , was performed without adequate measures to catch the counterboring shavin5s. When a flanged valve connection on the horizontal leg of ' spool C was made, the internal pipe cleanliners check was inadequately performed and the shavings were not discovered. b.) Failure to implement proper control of end-capping of installed pipe. The vertical leg of piping above 4"CV 2082-PB2-3 was left incomplete for over two years during which time the end cap may hgve become dislodged. Debris in spool B was out of sight around a 90 elbow and could not be seen during the pipe cleanliness check when the leg was completed. STP has reviewed this violation and agrees that deviations from project pipe cleanliness requirements existed. However, these deviations would have been found or rectified within the scope of existing STP pipe cleanliness controls, and would have no impact upon the safety of operations. The Piping System Cleanliness program for STP has controls designed to assure that an adequate level of cleanliness is achieved and maintained. The program was developed in recognition that pipe cleanliness is difficult to maintain over the duration of the construction period. Consequently, in addition to the controls applied during piping installation, cleaning of piping systems is required prior to release of the systems for preoperational testing. III. Corrective Action Taken and Results Achieved The following investigations and corrective actions have been made: 1.) A Non Conformance Report was issued to document the deviations. The identified debris was removed from the pipes. 2.) STP has performed a sample inspection to determine the extent of these deviations in Unit 2. Even though the problems were the result of work performed on vertical legs of pipe, some horizontal runs of pipe were also included in the sample. The inspection included approximately twenty percent (20%) of the vertically installed safety related piping in Unit 2. These inspections , L4/NRC/pp \\
-_. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ . *. . . , ' - , ,
,- . , . Attachment ST.HL.AE.1843
File No.: G2.4 Page 3 of 3 included the use of boroscopes on some of the completed pipin5 installations. Four (4) pipes in the sample had a small amount of debris in them. The presence of this debris would have no effect on the safe operation of the systems involved. These deviations represent approximately three percent (34) of the inspection sample. The debris was detected visually, without the aid of boroscopes and was removed at the time of the inspections. Due to the small number and the nature of the deviations identified, STP believes an acceptable level of pipe cleanliness exists in Unit 2. Due to the advanced stage of completion of Unit I wherein the proof of cleanliness flushes have been completed, STP does not consider corrective actions beyond emphasizing pipe cleanliness requirements to be necessary for that Unit. IV. Corrective Steps Taken to Prevent Recurrence To avoid recurrence of the types of deviations identified, STP has taken the following actions: 1.) All Unit 2 Piping Supervisors. Foremen, and General Foremen have been reinstructed to the requirements of the Standard Site Procedure with regard to internal pipe cleanliness (SSP-22). 2.) Unit 1 Pipin5 supervision was directed to emphasize $$P-22 requirements in piping installation. 3.) A program of documented weekly walkdowns in Unit 2 was initiated. Responsible Supervisors will perform the walkdowns to assure that all pipes have sealed ends. Pipes with seals missing will receivo a cleanliness inspection to assure that areas of the piping into which debris could enter and not be seen are checked. V. Date of Full Compliance STP is in full compliance at this time. 4 IA/NRC/pp . _. , . - - - . . . . - - . _ _ _ - . . - _ , _ - -. _ _ }}