ST-HL-AE-1700, Responds to NRC Re Violations Noted in Insp Repts 50-498/86-06 & 50-499/86-06.Corrective actions:in-core Instrument Tubes Inspected,To Ensure Correct Installation & Nonconformance Rept Written & Site Engineering Reinstructed

Responds to NRC Re Violations Noted in Insp Repts 50-498/86-06 & 50-499/86-06.Corrective actions:in-core Instrument Tubes Inspected,To Ensure Correct Installation & Nonconformance Rept Written & Site Engineering Reinstructed

ML20207E893
Person / Time
Site:	South Texas
Issue date:	07/08/1986
From:	Goldberg J HOUSTON LIGHTING & POWER CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20207E847	List: ML20207E843 ST-HL-AE-1700, Responds to NRC Re Violations Noted in Insp Repts 50-498/86-06 & 50-499/86-06.Corrective actions:in-core Instrument Tubes Inspected,To Ensure Correct Installation & Nonconformance Rept Written & Site Engineering Reinstructed
References
CON-#386-958 OL, ST-HL-AE-1700, NUDOCS 8607220444
Download: ML20207E893 (5)

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The Light NE Mf Ilouston Lighting & Power itO.11ox 1700 llouston. Texas 77001 (713)228-9211 July 8, 1986 ST-HL-AE-1700 File No. G2.4, M22.3

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Mr. Robert D. Martin Regional Administrator, Region IV gg U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 "-

y Arlington, Texas 76011 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violations 8606-01 and 8606-02

Dear Mr. Martin:

A detailed report addressing the subject violations was originally submitted via letter ST-HL-AE-1647 dated April 8, 1986 following the NRC exit meeting of April 4, 1986. Ilowever, Houston Lighting & Power Company (HL&P) submits the attached response to Notice of Violations 8606-01 and 8606-02 (50-498) dated June 24, 1986 pursuant to 10CFR2.201. Changes to the original report have been identified in this response for your convenience.

If you should have any questions on this matter, please contact Mr. S. M. Head at (512) 972-8392.

Very truly yours,

[

J.11. Goldberg i Group Vice President, Nuclear l

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Attachment:

Response to Notice of Violations 8606-01 and 8606-02 G

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. s ST-HL-AL-1700 llouston Lighting & Power Company File No.: C2.4, M22.3 Page 2 cc:

Hugh L. Thompson, Jr. , Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Robert D. Martin Lanny A. Sinkin Regional Administrator, Region IV Christic Institute Nuclear Regulatory C0aaission 1324 North Capitol Street 611 Ryan Plaza Drive, Suite 1000 Washington, D.C. 20002 Arlington, TX 76011 Oreste R. Pirfo, Esquire N. Prasad Kadambi, Project Manager Hearing Attorney U.S. Nuclear Regulatory Commission Office of the Executive Legal Director 7920 Norfolk Avenue U.S. Nuclear Regulatory Commission Bethesda, MD 20814 Washington, DC 20555 Claude E. Johnson Charles Bechhoefer, Esquire Senior Resident Inspector /STP Chairman, Atomic Safety &

c/o U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Washington, DC -20555 Bay City, TX 77414 Dr. James C. Lamb, III M.D. Schwarz, Jr. , Esquire 313 Woodhaven Road Baker & Botts Chapel Hill, NC 27514 One Shell Plaza Houston, TX 77002 Judge Frederick J. Shon Atomic Safety and Licensing Board J.R. Newman, Esquire U.S. Nucle:r Ecgulatc" - -

Newman & Holtzinger, P.C. Washington, DC 20555 1615 L Street, N.W.

Washington, DC 20036 Citizens for Equitable Utilities, Inc.

c/o Ms. Peggy Buchorn Director, Office of Inspection Route 1, Box 1684

, and Enforcement Brazoria, TX 77422 U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing & Service Section Office of the Secretary T.V. Shockley/R.L. Range U.S. Nuclear Regulatory Commission Central Power & Light Company Washington, DC 20555 P.O. Box 2121 (3 Copies)

Corpus Christi, TX 78403 Advisory Committee on Reactor Safeguards H.L. Peterson/G. Pokorny U.S. Nuclear Regulatory Commission City of Austin 1717 H Street P.O. Box 1088 Washington, DC 20555 Austin, TX 78767 J.B. Poston/A. vonRosenberg City Public Service Board P.O. Box 1771 San Antonio, TX 78296 Revised 5/22/86 14/NRC/ab.mg-1 L.

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• Attachment ST-HL-AE-1700 File No,': G2.4/M22.3 Page 1 of 3 Pages South Texas Project Units.1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violations 86-06-01 and 86-06-02 I. Statement of Violations Based on the results of an NRC inspect IJ n conducted during the period of February 17 through April 4,1986, and in accordance with the NRC Enforcement Policy (10CFR Part 2, Appendix C), the following violations were identified:

Failure to Perform. Work With an Approved Control Document (8606-01)

Criterion VI of Appendix B to 10 CFR Part 50 requires " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes there to, which prescribe all' activities affecting quality. These measures shall assure that documents, including changes are reviewed for adequacy and approved for.

release by authorized personnel and are' distributed to and used at the location where the prescribed activity is performed. . . . .

This requirement is part of the approved Quality Assurance Plan Description (QAPD) for South Texas Project.

Contrary to the above, work on the incore instrumentation system seal plate was performed without a work authorization. A Field Change Notice (FCN) authorizing work on the tube interchange was not generated, and work was performed utilizing a Westinghouse Field Deficiency Report (FDR). This is contrary to quality assurance procedures since a Westinghouse FDR is not an accepted craft work authorization.

Failure to Follow Procedure (8606-02)

Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate instructions, procedures, or drawings. This requirement is part of the approved QAPD for South Texas Project.

Contrary to the above, two thimble guide tubes on the incore instrumentation system were not connected at the seal plate hole locations as depicted by drawings 1216E28 and 1215E77, both Revision 7.

Quality Control inspectors approved all of the seal plate connections even though two were obviously misconnected.

II. Description of Problem In June 1985, it was determined that two pairs of instrument tubes would cross if installed at their original design location on the seal table.

A Construction Field Engineering " Request for Engineering Assistance (REA)" and a Westinghouse Field Deficiency Report (FDR) were prepared to document the drawing discrepancy and to request clarification of the i

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Attachment ST-HL-AE-1700 File No.: G2.4/M22.3 Page 2 of 3 Pages drawings to show the correct location of in-core instrumentation tubes that appeared to be transposed.

The Westinghouse disposition of the FDR required the tubing to be interchanged and the appropriate NSSS drawings to be revised to reflect the correct core locations on the seal table. The engineering response to the REA referenced the FDR. Upon receipt of the response to the REA, the Constructor proceeded with installation utilizing the REA as the design document. This is in violation of approved site procedures that require construction activities to be performed using controlled design, drawings, procedures and approved design change documents.

REA's and FDR's are not authorized to be used for construction activities at the South Texas Project.

The tubing connections to the seal plate were subsequently inspected and accepted by Quality Control although construction was not completed in accordance with the latest approved design documents.

Following turnover to the Startup organization, it was discovered that one pair of instrument tubes were installed at their original design location on the seal table resulting in these tubes being crossed.

Further investigation determined that the seal plate hole numbers for both pairs of instrument tubes had been marked in accordance with the FDR as opposed to the latest design drawing, and the other pair of instrument tubes had been interchanged in accordance with the disposition of the FDR.

The following are the root causes of these deficiencies:

o Construction performed work against an REA which is not proper design authorization, o The engineering response to the REA was not incorporated into approved Bechtel engineering design information and issued to construction for use, j o The Quality Control Inspector improperly inspected the installation against the existing design documents. This Inspector is no longer on site.

i III. Corrective Actions Taken and Results Achieved The following investigations to determine if unauthorized documents were used for other construction or inspection activities were performed:

t o A review of additional Inspection Reports did not disclose any other situation where an FDR was referenced for acceptance. Discussion with inspection personnel indicated that none were aware of any L4/NRC/ab.mg-1

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Attachment ST-HL-AE-1700 File No.: C2.4 /M22. 3 Page 3 of 3 Pages other situation where unauthorized documents were used for inspection and acceptance of construction work. An inspection of the remaining in-core instrument tubes was performed to ensure they were installed in their correct location on the seal plate. No other deficiencies were identified.

o A review of 100% of the closed Instrumentation and Controls (I&C)

REA's and approximately 70% of the closed I&C Mechanical, Piping, Pipe Supports, Welding and "Ceneral" REA's which pertain _to the Reactor Containment Building has been completed. All REA's directed Construction to perform work to an approved Bechtel design document.

A Nonconformance Report (NCR) was written to document the physical discrepancy. The NCR was dispositioned and the discrepancy corrected by realigning and rewelding the tubing in the proper locations.

IV. Corrective Steps Taken to Prevent Recurrence The Quality Control Site Supervisor reinstructed all Inspectors to perform inspections using only the latest approved engineering design documents.

Craft Supervisors and Field Engineers were reinstructed that REA's and FDR's must not be used for construction.

All appropriate I&C Engineers and. Supervisors have been reinstructed.

The appropriate Mechanical, Piping and Pipe Support Engineers and Supervisors have also been reinstructed.

The Site Office Engineering Manager has reinstructed Site Engineering of the requirement that since an REA in not a' design disclosure document, l response to REA's should reference the appropriate project design document which will feature the change.

I V. Date of Full Compliance HL&P was in full compliance with the requirements of 10CFR50, Appendix B and the approved Quality Assurance Plan Description on April 7, 1986.

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