ML20212E743
| ML20212E743 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/31/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8701050430 | |
| Download: ML20212E743 (2) | |
See also: IR 05000498/1986031
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DEC 311988
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,In Reply Refer To:
Dockets: 50-498/86-31
50-499/86-31
Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P, O. Box 1700
Houtton. Texas
77001
Gentlemen:
Thank you for your letter of Noveber 25, 1986, in response to our letter and
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Notice of Violation dated October 22, 1986. We have res iewed 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
detennine that full compliance has been achieved and will be maintained.
Sincerely,
'w.+u' c; rcri By:
q.t.'vt"
J. E. Gagliardo, Chief
Reactor Projects Granch
cc:
Houston Lighting & Power Company
ATTN:
M. Wisenberg, Manager,
Nuclear Licensing
P. O. Box 1700
Houston, Texas
77001
Brian Berwick, Esquire
Asst. Attorney General
Environmental Protection Division
P. O. Box 12548, Capitol Station
78711
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Houston Lighting & Power Company
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,
Lanny Alan Sinkin
Citizens Concerned About Nuclear
Power, Inc.
Christic Institute
1324 North Capitol Street
Washington, D.C.
20002
Charles Bechhoefer, Esquire
Chairnen, Atomic Safety & Licensing
Board
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Dr. James C. Lamb, III
313 Woodhaven Road
Chapel Hill, North Carolina
27514
Frederick J. Shon
Administrative Law Judge
Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Alvin H. Gutterman
Newman & Holtzinger, P.C.
1615 L St., N.W., Suite 1000
Washington, D.C.
20036
Texas Radiation Control Program Director
bec to DMB (IE01)
bec distrib. by RIV:
RPB
Project Inspectors (2)
RRI-0PS
R. D. Martin, RA
RRI-CONST.
SectionChief(RPB/C)
R&SPB
MIS System
RIV File
D. Weiss, RM/ALF
RSTS Operator
R. Pirfo, ELD
RSB
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The Light
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November 25, 1986
ST-HL-AE-1800
File No.: G2.4
V
Mr. Robert D. Martin
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Regional Administrator, Region IV
U. S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas
76011
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South Texas Project
Units 1 & 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8631-01/8631-01
Dear Mr. Martin:
Houston Lighting and Power Company (HL&P) has reviewed Notice of
Violation 50-498/8631-01, 50-499/8631-01 dated October 22, 1986, and submits
the attached response pursuant to 10CFR2.201. The housekeeping corrective
actions to prevent recurrence indicated herein also address the concerns
raised by USNRC Region IV Inspector J. E. Bess during his recent inspection.
If you should have any questions on this matter, please contact
Mr. S. M. Head at (512) 972-8392.
Very truly yours,
sY.
J. H. Goldberg
Group Vice President, Nuclear
WPE/hg
Attachment: Response to Notice of Violation (498/499-8631-01)
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ST-HL-AE-1800
ile No.: C2.4
Houston Lighting & Power Company
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cc:
Hugh L. Thompson, Jr. , Director
T.V. Shockley/R.L. Range
Division of PWR Licensing - A
Central Power & Light Company
Office of Nuclear Reactor Regulation
P.O. Box 2121
U.S. Nuclear Regulatory Commission
Corpus Christi, TX 78403
>
Washington, DC 20555
O. Backus/J. E. Malaski
Robert D. Martin'
City of Austin
Regional Administrator, Region IV
P.O. Box 1088
Nuclear Regulatory Commission
Austin, TX 78767
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
J. B. Poston/A. vonRosenberg
City Public Service Board
N. Prasad Yadambi, Project Manager
P.O. Box 1771
U.S. Nuclear Regulatory Commission
San Antonio, TX 78296
7920 Norfolk Avenue
Bethesda, MD 20814
Brian E. Berwick, Esquire
,
Assistant Attorney General for
Dan R. Carpenter
the State of Texas
Senior Resident Inspector / Operations
P.O. Box 12548, Capitol Station
c/o U.S. Nuclear Regulatory
Austin, TX 78711-
Commission
P.O. Box 910
Lanny A. Sinkin
Bay City, TX 77414
Christic Institute
1324 North Capitol Street
Claude E. Johnson
Washington, D.C.
20002
Senior Resident Inspector /STP
c/o U.S. Nuclear Regulatory
Oreste R. Pirfo, Esquire
Commission
Hearing Attorney
P.O. Box 910
Office of the Executive Legal Director
Bay City, TX 77414
U.S. Nuclear Regulatory Commission
Washington, DC 20555
M.D. Schwarz , Jr. , - Esquire
Baker & Botts
Citizens for Equitable Utilities, Inc.
One Shell Plaza
e/o Ms. Peggy Buchorn
Houston, TX 77002
Route 1, Box 1684
Brazoria, TX 77422
J.R. Newman, Esquire
Newman &'holtzinger, P.C.
Docketing & Service Section
1615 L Street, N.W.
Office of the Secretary
Washington, DC 20036
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Director, Office of Inspection
(3 Copies)
and Enforcement
U.S. Nuclear Regulatory Commission
Advisory Committee on Reactor Safeguards
Washington, DC 20555
U.S. Nuclear Regulatory Commission
1717 H Street
Washington, DC 20555
Revised 11/12/86
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Attachment
ST-HL-AE-1800
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File No.: C2.4
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Page 1 of 3
South Texas Project
Units 1 & 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8631 01/8631-01
I. Statement of the Violation
During an NRC inspection conducted on August 30 through October 3, 1986,
a violation of NRC requirements was identified. The violation involved
the component cooling water pump room.
In accordance with the "Ceneral
Statement of Policy and Procedure for NRC Enforcement Actions,"
10CFR Part 2, Appendix C (1986), the violation is listed below:
" Failure to Follow Inplace Storage Requirements
Criterion XIII of Appendix B to 10CFR50, states, in part, that
measures shall be established to control the handling, storage, and
preservation of material and equipment to prevent damage or
deterioration.
This requirement is amplified by Section 13 of the HL&P Quality
Assurance Program which requires that storage requirements be
promulgated in procedures and specifications to preclude damage and
deterioration.
Bechtel specification 5A300GS1002, Revision 8, paragraph 3.3D
requires in-place protection to minimize damage or degradation of
quality.
Contrary to the above, the "B" Component Cooling Water Pump, motor,
and other room accessories have not been adequately protected from
the overhead installation of fireproofing insulation resulting in a
deteriorating condition.
This is a Severity Level IV violation.
(Supplement I. E)
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(498/8631-01)"
II. Reason for Violation
The "B" CCW Pump, motor, and other accessories in the room were
inadequately protected due to poor coordination of construction and
start-up activities in the room.
Several Project organizations were
performing activities around the equipment.
These activities restricted
the installation of protective plastic over portions of the equipment.
Fireproofing was originally scheduled to be accomplished prior to
start-up activities. This work was delayed and was eventually performed
under a work release which was not coordinated to reflect the new status
of the room.
HL&P has determined that, even though there was a violation of in-place
protection requirements, the deficiency did not adversely affect the
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equipment.
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Attachment
ST-HL-AE 1800
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File No.: C2.4
Page 2 of 3
III. Corrective Actions Taken and Results Achieved
The fireproofing contractor has performed a thorough clean-up of the
area. This clean-up was in-progress at the time the violation was
identified. The contractor also installed additional scaffolding and
protective plastic over the component cooling water pumps, eliminating
the uncovered areas. HL&P has determined that the additional measures
were satisfactory.
Ebasco Construction issued a Standard Deficiency Report (SDR) to address
similar deficiencies in the area which were observed subsequent to the
NRC inspection. The area was cleaned to remove all debris from the CCW
pumps. Quality Assurance / Control (QA/QC) and Construction inspections of
surrounding areas and Unit 1 buildings have verified the overall in-place
protection of Unit 1 equipment to be satisfactory.
Equipment in the
inspected areas was adequately protected from construction related
activities.
IV. Corrective Steps Which Have Been Taken to Prevent Recurrence
The following additional actions have been taken:
A program has been implemented to enhance plant clean up efforts, to
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minimize possible equipment damage, and to ensure housekeeping
levels are acceptable for commercial operation. Actions included in
this program are
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Dedicated construction superintendents have been assigned whose
sole function is to ensure clean-up of the plant.
Startup has assigned personnel, by area, that are responsible
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for coordinating cleanliness activities with construction.
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Permanent plant equipment will be cleaned (as needed) on a
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daily basis,
Ebasco management has discussed this issue with the Discipline
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Managers in meetings, emphasizing their responsibilities in the
areas of in-place protection and housekeeping.
These discussions
re-emphasized the matrix developed to identify individuals
responsible for maintaining areas and equipment in compliance with
site requirements. This matrix was developed to improve overall
housekeeping and in-place protection.
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File No.: G2.4
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Page 3 of 3
QC' personnel responsible for surveillance of housekeeping and
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in-place protection of equipment have been given a copy of the
matrix to assist in the resolution of problems. Ebasco has
designated a manager to administer this program. He is to be the
. central contact for the resolution of concerns if action by the
primary contact is not "qdequrte.
A program has been established to address housekeeping and in-place
o
protection concerns which require swift resolution to prevent the
degradation of equipment.
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.Bechtel management has issued a directive to all appropriate
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organizations, including contractors, directing improvement on
performance and coordination of activities to prevent additional
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problems. Attached to..this directive are the matrix of Constructor
individuals responsible for maintaining housekeeping and in-place
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protection in plant . areas and the list of personnel from other
'ur6anizationa,.(Sta'rtup, Bechtel Contracts), responsible to
coordinate rasolution of problems identified.
A Quality Talk has been given.to Construction personnel emphasizing
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the need to comply with the requirements for in-place protection and
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housekeeping.
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In conjunction with the Quall'ty Talk, an article was included in the
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site newsletter to improve o terall jobsite familiarization with this
situation.
HL&P executive management has. admonished its Operations Department
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to pe'esonally oversee residual construction work activities
affecting system's, equipment, or facilities turned over to HL&P to
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assure that the work is carried out with proper regard for the
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physical protection of such systems, equipment, or facilities.
We believe the abov'e~9tions provide assurance that the project can be
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maintained in a clean. condition and that appropriate and timely actions
are tiken should future situations result in a deficient condition.
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V. Date of Full Compliance
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The project is pr6sently'in full compliance.
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