ML20237G253
| ML20237G253 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/18/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237G240 | List: |
| References | |
| 50-498-87-39, 50-499-87-39, NUDOCS 8708240021 | |
| Download: ML20237G253 (3) | |
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i APPENDIX A NOTICE OF VIOLATION
' Houston Lighting & Power Company Dockets:
50-498' South Texas Project, Units 1 & 2 50-499 Permits:
CPPR-128 CPPR-129 During an NRC inspection conducted May 30 through June 26, 1987, two violations of NRC requirements were identified.
The violations involved failure to follow procedures for performing preoperational tests and installing temporary modifications.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
Failure to Follow Procedures for Performing Preoperational Tests Criterion V, Appendix B to 10 CFR 50 requires, in part, that activities affecting quality be prescribed by documented procedures and accomplished in accordance with these procedures.
Six examples of failure to follow I
these procedures are listed below.
1.
Startup Administrative Instruction (SAI) 18, Revision 5, "Preoperational Testing," is an approved procedure covering the performance of activities affecting quality.
Step 5.3.6 of SAI 18 requires that restoration of temporary alterations include dual verification.
Contrary to the above, Step 5.3.6 of SAI 18 was not followed in that Step 7.2.33 of Preoperational Test Procedure 1-CS-P-03, " Containment Spray Train C," which involved restoration of a temporary alteration did not contain an initial. indicating a second verification of restoration of the temporary alteration.
2.
Preoperational Test Procedures 1-CC-P-01, " Component Cooling Water System Train A"; 1-CC-P-02, " Component Cooling Water System Train B";
1-CC-P-03, " Component Cooling Water System Train C"; and 1-CC-P-04,
" Component Cooling Water System Balance" are approved procedures covering the performance of activities affecting quality.
Contrary to the above, requirements of these procedures involving dual verification were not followed in that:
1 a.
Steps 7.29.11 and 7.29.13 of 1-CC-P-01 were initialed indicating f
dual verification of a temporary alteration at j
Instrument 1-CC-FY-4494 when the correct instrument number was later indicated as 1-CC-TY-4494.
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' Final verificati_on in Step 7.5.10.1 of Procedure 1-CC-P-01 was not made until after the completion of Section 8.0 contrary to the. requirement of Precaution ~6.4 of 1-CC-P-01.
c.
Steps 7.26.88.1 and 7.26.102.1 of Procedure 1-CC-P-02 were initialed indicating dual-verification of a temporary alteration;.however, after the completion of the procedure, the specified cables and instruments were found not to be associated with each other.
d.
Step 7.26.144.4.of Procedure CC-P-02 contained dual verification initials; however, after the completion of the procedure, the J
referenced instrument number was identified as incorrect.
e.
Final verification'in Step 7.25.97.2 of Procedure 1-CC-P-03 was not made until after completion of Section 8.0 contrary to the requirement of Precaution 6.4 of 1-CC-P.-03.
This.is a'_ Severity Level IV violation.
(Supplement II)(498/8739-01)
B.
Failure to Follow Procedures for' Installing Temporary' Modifications Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality be prescribed by documented instructions or procedures and shall be accomplished in accordance with these procedures.'
The STP Operations Quality Assurance Plan implements this requirement for operation.
Procedure OPGP03-20-0003, " Temporary Modifications and Alterations,i' requiras the system engineer to perform a Licensee Compliance Review and attach it to the temporary modification request and requires Plant Operations Review Committee (PORC) review and plant manager approval to be obtained within 14 days of installing the modification.
Contrary to the above,. on June 24, 1987, it was found that Temporary Modification Request T1-DG-87-123 installed on May 23, 1987, and restored on June 19, 1987, did not receive a License Compliance Review, PORC review, and/or plant manager approval although it had been forwarded to document control as a completed quality assurance record.
Also, Temporary Modification Request T1-D0-87-122 installed'on May 15, 1987, had not received PORC review or plant manager approval as of June 22, 1987.
This is a Severity Level IV violation.
(Supplement II)(498/8739-02)
Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to this Office within 3J days of the date of the letter transmitting this Notice.
This reply, should include for each violation:
(1) the reason for the violations if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further w_
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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.
Dated at-Arlington, Texas, this
/f4.6 day of d< x d 1987..
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