ML20214E735
| ML20214E735 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/17/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8611250077 | |
| Download: ML20214E735 (2) | |
See also: IR 05000498/1986023
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NOV 171986
- In Reply Refer To:
Dockets: 50-498/86-23
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 November 3,1986, in response to our letter
and Notice of Violation dated October 8,1986. 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,
OrfJ.ina! Sknod By
J. E. Gagliardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Houston Lighting & Power Company
ATTN:
M. Wisenberg, M:,1ager,
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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Lanny Alan Sinkin
Citizens Concerned About Nuclear
Power, Inc.
Christic Institute
1324 North Capitol Street
Washington, D.C.
20002
Charles Bechhoefer, Esquire
Chairman, 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
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November 3,1986
ST-HL-AE-1747
File No.: G2.4
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Mr. Robert D. Martin
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Regional Administrator, Region IV
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U. S. Nuclear Regulatory Commission
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611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas
76011
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South Texas Project
Units 162
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8623 02
Dear Mr. Martin:
Houston Lighting & Power Company has reviewed Notice of Violation
50 498/8623-02 dated October 8, 1986 an( submits the attached response
pursuant to 10CFR 2.201.
If you should have any questions on this matter, please contact
Mr. S.M. Ilead at (512) 972-8392.
Very truly yours,
J. H. Goldberg
Group Vice President, Nuclear
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Attachment:
Response to Notice of Violation 8623-02
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ST-HL-AE-1747
Ilouston Lighting & Power Company
File No.: G2.4
Page 2
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cc:
Fugh L. Thompson, Jr. , Director
J. B. Poston/A, vonRosenberg
Division of PWR Licensing - A
City Public Service Board
Office of Nuclear Reactor Regulation
P.O. Box 1771
U.S. Nuclear Regulatory Commission
San Antonio, TX 78296
Washington, DC 20555
Brian E. Berwick, Esquire
N. Prasad Kadambi, Project Manager
Assistant Attorney General for
U.S. Nuclear Regulatory Commission
the State of Texas
7920 Norfolk Avenue
P.O. Box 12548, capitol Station
Bethesda, MD 20814
Austin, TX 78711
Claude E. Johnson
Lanny A. Sinkin
Senior Resident Inspector /STP
Christic Institute
c/o U.S. Nuclear Regulatory
1324 North Capitol Street
Commission
Washington, D.C.
20002
P.O. Box 910
Bay City, TX 77414
Oreste R. Pirfo, Esquire
Hearing Attorney
M.D. Schwarz , J r. , Esquire
Office of the Executive Legal Director
Baker & Botts
U.S. Nuclear Regulatory Commission
One Shell Plaza
Washington, DC 20555
llouston, TX 77002
Citizens for Equitable Utilities, Inc.
J.R. Newman, Esquire
e/o Ms. Peggy Buchorn
Newman & IIoltzinger, P.C.
Route 1, Box 1684
1615 L Street, N.W.
Brazoria, TX 77422
Washington, DC 20036
Docketing & Service Section
Director, Office of Inspection
Office of the Secretary
and Enforcement
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20555
(3 Copies)
T.V. Shockley/R.L. Range
Advisory Committee on Reactor Safeguards
Central Power & Light Company
U.S. Nuclear Regulatory Commission
P.O. Box 2121
1717 11 Street
Corpus Christi, TX 70403
Washington, DC 20555
A. Backus/J. E. Malaski
City of Austin
P.O. Box 1088
Austin, TX 78767
Revised 10/09/86
L4/NRC/f/mg 0
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Attachment
ST-HL AE-1747
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File No.: C2.4
Page 1 of 4
South Texas Project
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Units 1 & 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8623-02
I.
Statement of Violation
Criteria V of Appendix B to 10 CFR Part 50, requires activities affecting
quality be prescribed by and accomplished in accordance with appropriate
instructions, procedures, or drawings. This requirement is amplified by
the approved QAPD for South Texas Project. The following are examples of
failures to meet this requirement.
1.
SSP-9.0, Revision 4, paragraph 5.2.7.3 states, "that all work on
permanent or temporary supports which are released for test shall
require a Startup Work Request (SWR) before any work can be
performed."
Contrary to the above, construction craft removed the main steam
piping temporary supports in Isolation Valve cubical (IVC) A and C
without a SWR which resulted in an overload condition of the main
steam line.
2.
Specification SL340JS1002, Revision 10, paragraph 5.4.4.5 states, in
part, that deviations in the actual cold position are permitted to
account for slight imbalance. The constructor shall check / verify to
assure that this deviation will not result in bottoming out or
topping out of the spring hangers due to thermal or seismic
movements of the pipe.
Contrary to the above, construction craft did not check / verify the
main steam (MS) line in Unit 1 IVC A and C after hydrostatic testing
resulting in the bottoming out of spring hangers MS1001-HL5013 and
MS1003-HL5018.
3.
Specification 5L340JS1002, Revision 10, paragraph 5.4.4.7 states
" travel stops in variable springs may be removed, as directed by
engineering, to facilitate system testing."
l
Contrary to the above, travel stops in variable spring hangers
l
MS1001-HL5013 and MS1003 HL5018 were removed without approval from
engineering.
This is a Severity Level IV violation.
(10CFR Part 2, Supplement 1.E.)
(498/8623-02)
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Attachment
ST-HL-AE-1747
File No.: G2.4
Page 2 of 4
II. Reason for Violation
The root cause of this Violation has been determined to be a lack of
attention by construction personnel to applicable project requirements for
removal of temporary supports and travel stops, verification of spring hangers
for bottoming out or topping out conditions, and a misinterpretation by
Quality Control (QC) personnel of procedural requirements for removal of
travel stops.
System testing may require removal of some travel stops, as
directed by Engineering in the Engineering Pipe and Pipe Supports Evaluation
Sheets (also called Hanger Adequacy Letters); however, verification of the
status of travel stops prior to hydrostatic test was not performed. QC
assumed that the issuance of the Adequacy Letter by Engineering provided the
necessary verification.
~
III. Corrective Action Taken And Results Achieved
An investigation of the situation was performed and the following
documents were issued to assess and correct the problem: (i)
Nonconformance Reports (NCR's) CS-03998, CS-03999, CS 04008 and CS-04039
were prepared to document the nonconforming conditions, (ii) Stop Work
Notice 86-03 was issued to prevent any further unauthorized work on the
affected Main Steam Lines within the Unit 1 IVC (The Stop Work Notice was
lifted after completing the investigation), (iii) Engineering Problem
Investigation Report 86-5029 was issued to evaluate the reported
condition and determine the necessary corrective action, (iv) Deficiency
Evaluation Report 86-037 was issued to evaluate the condition for
potential reportability pursuant to 10CFR50.55(e) and 10CFR part 21
requirements.
To assess the overall status of temporary and permanent supports, a walk-
down was performed on other piping systems containing a total of one
hundred and sixteen (116) permanent and temporary supports. These
supports were found to be installed in accordance with the project
requirements.
Supports with spring hangers were inspected to assure that
the travel stops were in place as required. Additionally, it was
verified that permanent and temporary supports were properly tagged.
,
Craft and field engineering personnel were retrained on the requirements
for the removal of travel stops and temporary supports.
The training was
based on the controls in place at the time this problem occurred, and
stressed that temporary supports and travel stops must not be removed
without Engineering approval.
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Attachment
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File No.: G2.4
Page 3 of 4
Temporary supports for the main steam lines were immediately provided to
preclude further pipe movement.
In addition, an analysis of the stresses
imposed on the permanent plant supports, piping and associated structures
has been performed. Analysis has shown that the deficiency did not
result in overstress of the main steam lines, permanent plant supports,
or associated structures. NCR dispositions are based on the results of
the stress analysis.
IV. Corrective Steps Which Have Been Taken To Prevent Recurrence
In addition to the above, the following actions have been taken to
prevent recurrence of the problem:
Specification SL340JS1002 " Pipe Support Field Fabrication and
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Installation", for controls of permanent plant hangers, temporary
supports and spring hanger travel stop installation and removal was
reviewed and found to be adequate. However, the specification has
been clarified to better define the project requirements related to
travel stops,
Standard Site Procedure SSP 2 " Project Generic Pressure Test
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Procedure", was reviewed to determine if appropriate controls were
specified for work performed on spring hanger travel stops and
essential supports required for hydrostatic test and was found to be
adequate. However, SSP-2 was revised to clatify its intent to avoid
any possible misinterpretation of project requirements regarding
removal of travel ntops. The revision also included requirements
for QC to verify, during the walkdown prior to hydrostatic test,
that spring hanger travel stops are either in place or removed in
accordance with Engineering direction given in the Hanger Adequacy
Letter.
In addition, Field Engineering will verify that spring
hangers are not bottomed or topped out.
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Standard Site Procedure SSP 9 " Pipe Support Installation" was
reviewed to determine if appropriate controls were specified for
temporary and permanent support installation and was found to be
adequate.
However, SSP-9 has been revised to clarify the
requirements for Design Engineering approval of work on temporary or
permanent supports after release for test and to clarify the
requiremonts that permanent supports be installed and that Field
Engineering approval be obtained prior to the remeval of temporary
supports.
In addition, the revision added the requirement for QC to
verify that spring hanger travel stops have been removed as required
for system balancing and that documentation to support balancing is
available.
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ST-HL-AE-1747
File No.: G2.4
Page 4 of 4
Standard Site Procedure SSP-36 " Construction Work Package" was also
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revised to include a requirement for Field Engineering to approve
the removal of a temporary support after its associated permanent
support is installed.
This will ensure that a permanent support is
functional prior to the removal of the temporary support.
Appropriate Construction and QC personnel have received training on the
requirements of the revised procedures.
V Date of Full Compliance
STP is in full compliance at this time.
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