ML20212P666

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/86-26 & 50-499/86-24

ML20212P666
Person / Time
Site:	South Texas
Issue date:	03/11/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8703160188
Download: ML20212P666 (1)

See also: IR 05000498/1986026

Text

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MAR 111387

In Reply Refer To:

Deckets: 50-498/86-26

50-499/86-24-

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 8,1987, in response to our le.tter and

Notice of Violation dated December 10, 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

i Houston, Texas 77001

Texas Radiation Control Program Director

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January 8, 1987 i

10CFR2.201 l

ST-HL-AE-1853

File No.4-G2.4 r--

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JAN I 21987  :

U. S. Nuclear Regulatory Commission

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Attention: Document Control Desk j l

Washington, D.C. 20555 - - - -"-

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South Texas Project j

Units 1 & 2

Docket Nos. STN 50-498, STN 50-499 j

Response to Notice of Violation 8626-01/8624-01 '

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Houston Lighting & Power Company has reviewed Notice of Violation .

498/8626-01; 499/8624-01 dated December 10, 1986 and submits the attached I

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. Goldberg

Group Vice President, Nuclear

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Attachment: Response to Notice of Violation 86-26-01/86-24-01

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Houston Lighting & Power Company 4

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cc:

Regional Administrator, Region IV M.B. Lee /J. E. Malaski

Nuclear Regulatory Commission City of Austin

611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088

Arlington, TX 76011 Austin, TX 78767

N. Prasad Kadambi, Project Manager A. vonRosenberg

'U.S. Nuclear Regulatory Commission City Public Service Board

7920 Norfolk Avenue P.O. Box 1771

Bethesda, MD 20814= San Antonio, TX 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.-Carpenter

Senior Resident Inspector / Operations Lanny A. Sinkin

c/o U.S. Nuclear Regulatory Christic Institute

Commission 1324 North Capitol Street

P.O. Box 910 Washington, D.C. 20002

Bay City, TX 77414

-

Oreste R. Pirfo, Esquire

-

Claude E. Johnson Hearing Attorney

Senior Resident Inspector /STP Office of the Executive Legal Director

c/o U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission

Commission Washington, DC 20555

P.O. Box 910

Bay City, TX 77414 Citizens for Equitable Utilities, Inc.

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c/o Ms. Peggy Buchorn

M.D. Schwarz, Jr. , Esquire Route 1, Box 1684

Baker & Botts Brazoria, TX 77422

One Shell Plaza

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Houston, TX 77002 Advisory Committee on Reactor Safeguards

U.S. Nuclear Regulatory Commission

J.R. Newman, Esquire 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

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Attachment

ST-HL-AE-1853

.. File No.: G2.4

Page 1 of 3

South Texas Project

Units 1 & 2

Docket Nos. STN 50-498, STN 50-499

Response to Notice of Violation 8626-01/8624-01

I. Statement of Violation

,

During an NRC inspection conducted on September 1 through

November 3, 1986, a violation of NRC requirements was identified. The

violation involved failure to follow procedures for dealing with

nonconforming items. In accordance with the " General Statement of Policy

,

and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C

(1986), the violation is listed below:

Criterion V of 10CFR50, Appendix B, requires that activities

affecting quality be prescribed by documented instructions or

procedures, and shall be accomplished in accordance with these

instructions or procedures. The South Texas Quality Assurance Plan,

Section 5 implements this requirement. Standard Site Procedure

(SSP) 8, "Nonconformance Reporting," Section 5.2.11.6 requires that

when nonconforming items are being transferred, e.g. betwoon

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construction and operations, the organization involved must transfer

the appropriate documents such as hold tags.

SSP-8 Section 5.2.11.6 also requires that when transferring

nonconforming items they will be properly tagged.

Contrary to the above, on August 8, 1986, the NRC inspector observed

an installed valve, DO-0132, serial number EG 288-40-4, in the

diesel fuel oil (DO) system with a construction hold tag attached.

The DO system had been turned over to startup and should have had an

operations hold tag attached.

Also on September 23, 1986, the NRC inspector noted that the

licensee had failed to transfer the hold tag, which indicated a

damaged shaft and bearings, on the 1A Centrifugal Charging Pump to

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the damaged shaft and bearings after they were replaced on August 4,

1986.

II. Reason for Violation

As a result of the hold tag problem identified on the diesel fuel oil

valve, HL&P initiated an extensive evaluation of the site equipment

transfer program to ensure uncontrolled nonconforming items are not

transferred to or installed in Unit 1 safety related systems. The

subsequent surveillances identified additional deficiencies concerning

Unit i nonconforming items that are transferred or replaced. The

deficiency types identified can be grouped as follows.

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Attachment

ST-HL-AE-1853

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File No.: G2.4

Page 2 of 3

A. Nonconforming information not being put on Transfer and Replacement

Request (TRR) forms. (A Transfer and Replacement Request is the

document used to transfer equipment from one unit to another.)

B. Inadequate documentation trail

C. Inadequate administrative control of TRR's

r D. Inadequate Transfer and Tagging of components parts

, E. NCR's closed and tags pulled prior to completion of disposition.

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l F. NCR's not being revised to indicate transfer status

G. Nonconforming items being interchanged prior to NCR initiation and

or disposition

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Immediate steps were taken to ensure control of nonconforming items.

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,~, Quality Assurance performed surveillances of the nonconformance and

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transfer request programs. These surveillances identified a programmatic

l deficiency. This deficiency was the subject of a report in accordance

with 10CFR50.55(e) made October 30, 1986.

The root cause of this problem is twofold:

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o failure to implement TRR procedure requirements due to lack of

familiarity on the part of personnel responsible for completing

TRRs, and

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l o a procedural omission in that pre-Release for Testing (RFT)

nonconformance transfer techniques did not adequately address

nonconforming items still in the warehouse.

III. Corrective Action Taken and Results Achieved

The following corrective actions have been taken with regard to the

identified discrepancies:

o A review of open Nonconformance Reports (NCRs), that had-been

converted from Construction jurisdiction to Startup was performed to

verify proper transfer / tagging status. The review and subsequent

correction (retagging) was completed October 16, 1986.

o A review was performed on open, Non "S" (other than start up) single

system and multiple system NCRs issued through September 30, 1986,

to ensure accurate tracking of non-conforming items. Deficiencies

of an administrative nature were identified. No significant

hardware deficiencies were identified. All deficiencies have been

corrected.

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Attachment

ST-HL-AE-1853

. File No.: C2.4

Page 3 of 3

o A review was performed of safety related, Quality Class 7 and a

random sample of non-safety related TRRs issued through

September 30, 1986 to ensure accurate tracking of nonconforming

items. Deficiencies of an administrative nature were identified and

.are being corrected. No additional hardware deficiencies were

identified.

IV. Corrective Steps Taken to Prevent Recurrence

A training session in TRR requirements was conducted for personnel

responsible for TRR preparation, processing, and approval.

Site Procedure SSP-8 (Nonconformance Reporting) was revised to clarify

tagging requirements for material in the warehouse that is designated for

systems turned over to Startup as well as for material returned to the

warehouse by Startup.

- Site Procedure SSP-48 (Equipment or Component Interchange) was revised to

establish a TRR material group to coordinate and track transferred

material.

V. Date of Full Compliance

Documentation of all the discrepancies was completed by December 22,

1986. STP is in full compliance. However, additional administrative

corrective actions and QA verifications by Bechtel and HL&P will continue

and be completed by February 15, 1987.

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