ML20211K686

Notice of Violation from Insp on 860217-0404

ML20211K686
Person / Time
Site:	South Texas
Issue date:	06/24/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211K683	List: IR 05000498/1986006 ML20211K678 ML20211K686
References
50-498-86-06, 50-498-86-6, 50-499-86-06, 50-499-86-6, NUDOCS 8606300218
Download: ML20211K686 (2)

Text

P APPENDIX A NOTICE OF VIOLATION Houston Lighting & Power Company Dockets: 50-498 South Texas Project, Units 1 and 2 50-499 Permits: CPPR 128 CPPR 129 During this NRC inspection conducted on February 17 through April 4,1986, three violations of NRC requirements were identified. The violations involved failure to follow procedures, failure to provide adequate inplace storage protection, and work performed without an approved control document. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:

A. Failure to Perform Work With an Approved Control Document Criterion VI of Appendix 8 to 10 CFR Part 50 requires " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes there to, which prescribe all activities affecting quality. These measures shall assure that documents, including changes are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed . . . ." This requirement is part of the approved Quality Assurance Plan Description (QAPD) for South Texas Project.

Contrary to the above, work on the incore instrumentation system seal plate was performed without a work authorization. A Field Change Notice (FCN) authorizing work on the tube interchange was not generated, and work was performed utilizing a Westinghouse Field Deficiency Report (FDR). This is contrary to quality assurance procedures since a Westinghouse FDR is not an accepted craft work authorization.

This is a severity Level IV violation. (Supplement II.D) (498/8606-01)

B. Failure to Follow Procedure Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate instructions, procedures, or drawings. This requirement is part of the approved QAPD for South Texas Project.

Contrary to the above, two thimble guide tubes on the incore instrumentation system were not connected at the seal plate hole locations as depicted by drawings 1216E28 and 1215E77, both Revision 7. Quality Control inspectors approved all of the seal plate connections even though two were obviously misconnected.

This is a severity Level IV violation. (Supplement II.D) (498/8606-02) 8606300218 860624 PDR ADOCK 05000498 G PDR

2 C. Failure to Provide Adequate Inplace Storage Protection Criteria XIII of Appendix B to 10 CFR Part 50 requires that measures be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. This requirement is amplified by the approved QAPD of South Texas Project.

Specification 5A300GS1002, Revision 8, paragraph 3.3, states that the following definition shall be used to identify the status of equipment materials which are requisitioned from Bechtel storage and to provide clarification of protection requirements:

3.3(c) Installed - Placed in its final (design) location. Installed equipment shall be afforded "Inplace Protection" to prevent degradation of the equipment.

Contrary to the above, there was dust, dirt, and physical damage to Unit 1 auxiliary feedwater pumps due to inadequate inplace storage protection.

This is a Severity Level IV violation. (Supplement II.D) (498/8606-03)

Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit, except as noted below, to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, (3) 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, consideration will be given to extending the response time. You are not required to submit a statement relative to item C, above, since it has been determined that adequate corrective actions have been taken.

Dated at Arlington, Tex 9s, this 2(M4 day of (A, ,,, 1986.

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