ML20236R436
| ML20236R436 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/19/1987 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8711230279 | |
| Download: ML20236R436 (2) | |
See also: IR 05000498/1987027
Text
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NDY 191987;
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In Reply Refer To:
Dockets:
50-498/87-27
50-499/87-27
Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P. 0. Box 1700
Houston, Texas
77001
Gentlemen:
Thank you for your, letter of September'28.- 1987 . in' response to- our letter
and Notice of Violation dated August 28, 1987. 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
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A.D. Beach
L. J. Callan, Director
{DivisionofReactorProjects
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Houston Lighting & Power Company
ATTN:
M. Wisenberg, Manager,
Nuclear Licensing
P. O. Box 1700
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Houston, Texas
77001
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Houston Lighting & Power Company
ATTN: Gerald E. Vaughn, Vice President
Nuclear Operations
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P. O. Box 1700
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Houston, Texas
77001
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Ccrpus Christi, Texas
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City Public Service Board
ATTN:
R. J. Costello/M. T. Hardt
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P. 0. Box 1771
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San Antonio, Texas
78296
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Texas Radiation Control Program Director
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P. Kadambi, NRR Project Manager
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September 28, 1987
ST-HL-AE-2337
File No.: G2.4
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U. S. Nuclear Regulatory Commission
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Attention:
Document Control Desk
20555
South Texas Project
Units 1 and 2
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Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8727-01
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Houston Lighting & Power Company has reviewed Notice of Violation 8727-01
dated August 28, 1987, and submits the attached response pursuant to
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If you should have any questions on this matter, please contact Mr.
J. S. Phelps at (512) 972-7071.
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J. H. Goldberg
Group Vice President, Nuclear
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Attachment:
Response to Notice of Violation 8727-01
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ST-HL-AE-2337
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File No.: G2.4
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11ouston Lighting & Power Company
Page 2
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CC:
Regional A&ninistrator, Region IV
M.B. Lee /J.E. Malaski
Nuclear Regulatory Ccmmission
City of Austin
611 Ryan Plaza Drive, Suite 1000
P.O. Box 1088
Arlington, TX 76011
Austin, TX 78767-8814
N. Prasad Kadambi, Project Manager
A. von Rosenberg/M.T. Hardt
U.S. Nuclear Regulatory Commission
City Public Service Board
7920 Norfolk Avenue
P.O. Box 1771
Bethesda, MD 20814
San Antonio, TX 78296
Dan R. Carpenter
Advisory Committee on Reactor Safeguards
Senior Resident Inspector / Operations
U.S. Nuclear Regulatory Commission
c/o U.S. Nuclear Regulatory
1717 H Street
Commission
Washington, DC 20555
-
P.O. Box 910
Bay City, TX 77414
Claude E. Johnson
Senior Resident Inspector / Construction
c/o U.S. Euclear Regulatory
Commission
P.O. Box 910
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Bay City, TX 77414
M.D. Schwarz, Jr., Esquire
Baker & Botts
One Shell Plaza
Houston, TX 77002
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J.R. Newman, Esquire
Newman & Holtzinger, P.C.
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1615 L Street, N.W.
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Washington, DC 20036
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R.L. Range /R.P. Verret
Central Power & Light Company
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P. O. Box 2121
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Corpus Christi, TX 78403
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Revised 07/16/87
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Attachment 1
.: $
4
ST-HL-AE-2337
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File No.: G2.4
Page 1 of 2
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South Texas Project
Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Violation 8727-01
I. Statement of Violation
" Criterion V, Appendix B of 10 CFR Part 50 requires that activities
affecting quality be prescribed by and accomplished in accordance with
appropriate instructions.
The specification for piping erection and
field fabrication, Specification 5A010PS0002, requires that external
surfaces of stainless steel shall be free of organic films and
cor,taminants such as oil, paint, and preservatives.
" Contrary to the above, the NRC inspectors observed that the external
surfaces of the discharge piping of the containment spray pumps, the high
head safety injection pumps, and the low head safety injection pumps were
spattered with paint, insulation glue, and lubricants."
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II. Reason for Violation
During coating and insulation activities, inadequate protection was
provided to surrounding equipment and piping.
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III. Corrective Action Taken and Results Achieved
Actions taken to correct the deficiencies are complete. The insulation
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contractor (PCI, Incorporated) conducted an inspection of insulated
equipment and components in areas where the potential existed for
adhesive spillage or splattering on stainless steel piping.
PCI found no
additional cases. The insulation adhesive (Rubatex) is known to be
unacceptable for coating stainless steel equipment.
Spilled and/or
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splattered Rubatex which was found on stainless steel piping was removed.
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PCI also retrained its personnel to ensure that the cleanliness and
protection requirements of site specification 5A010PS0002 are maintained
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during insulation installation.
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Ebasco Constructors, Incorporated (ECI) also performed a reinspection
program for piping in both units. The reinspection program identified
additional instances of foreign material on the exterior of stainless
steel pipe. These cases were documented on Nonconformance Reports
(NCRs). Apart from the Rubatex, the foreign material found on the piping
was determined to have acceptable levels of halogens and would not
adversely effect the stainless steel pipe. Therefore, the oil / grease,
paint, and tape residue identified on the pipe in the reinspection did
not need to be removed. As stated above, PCI removed the Rubatex.
L4/NRC/a/hg-0
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Attachment 1
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ST-HL-AE-2337
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File No.: G2.4
Page 2 of 2
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IV. Corrective Steps Taken to Prevent Recurrence
In addition to the retraining of PCI personnel, ECI coatings applicators,
foremen, and general foremen were reinstructed on the requirements for
protecting adjacent equipment and piping during coatings activities.
Site procedures which govern coatings activities were revised to clarify
,
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and enhance these requirements.
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STP will include an examination of the external cleanliness of stainless
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steel pipe in the normal housekeeping activities for Unit 2.
Discrepancies identified will be remedied in accordance with approved
site procedures.
Current site procedures require an inspection of stainless steel pipe
which is to be insulated prior to installation of the insulation.
In
addition to this requirement, uninsulated stainless steel pipe will be
inspected to insure adequate external cleanliness prior to fuel load
of Unit 2.
Discrepancies will be remedied in accordance with approved
site procedures.
V. Date of Full Compliance
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STP is in full compliance at this time.
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