View source for ST-HL-AE-1363, Responds to NRC Re Violations Noted in Insp Repts 50-498/85-06 & 50-499/85-06.Corrective Actions:Deficiency Rept M-0576 Issued & Retorquing of Bolts Performed

{{Adams
| number = ML20133K955
| issue date = 09/13/1985
| title = Responds to NRC Re Violations Noted in Insp Repts 50-498/85-06 & 50-499/85-06.Corrective Actions:Deficiency Rept M-0576 Issued & Retorquing of Bolts Performed
| author name = Goldberg J
| author affiliation = HOUSTON LIGHTING &amp; POWER CO.
| addressee name = Martin R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000498, 05000499
| license number = 
| contact person = 
| case reference number = CON-#485-532
| document report number = OL, ST-HL-AE-1363, NUDOCS 8510220360
| title reference date = 08-16-1985
| package number = ML20133K944
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

=Text=
{{#Wiki_filter:r The Light NE              f flouston 1.ighting & Power I!O. Box 1700 Ilouston. Texas 77001 (713)228-9211 n n ,, eq                  September 13, 1985 T  __.
                                                           ! -              ST-HL-AE-1363
                                   )                       I                 File No.: G2.4 l                         M22.3 SEP i 6005        :1                          Q17.1.1
                                                       .__h;-                           P11.1 1.
Mr. Robert D. Martin Regional Administrator, Region IV Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violation 8506-01

==Dear Mr. Martin:==

Houston Lighting and Power Company (HL&P) has reviewed Notice of Violation 50-498/8506-01, 50-499/8506-01 dated August 16, 1985 and submits the attached response pursuant to 10CFR2.201.
If you should have any questions regarding this matter, please contact Ms. F. A. White at 512-972-8392.
Very truly yours,
                                                                         . 7''.          w :: _- ,
                                                                      '. H. Goldberg Group Vice President, Nuclear JHG/FAW/jlk

==Attachment:==
Response to Notice of Violation (8506-01)
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ST-HL-AE-1363
  ' -                                                                                    File No.: G2.4 0M22.3 Houston Lighting & Power Company                         Page 2 cc:
Hugh L. Thompson, Jr., Director         Brian E. Berwick, Esquire Division of Licensing                  Assistant Attorney General for Office of Nuclear ~ Reactor Regulation     the State of Texas U.S. Nuclear Reguiatory Commission     P. O. Box 12548, Capitol Station Washington, DC 20555                    Austin, TX 78711 N. Prasad Kadambi, Project Manager     Lanny A. Sinkin U.S. Nuclear Regulatory Commission      3022 Porter Street, N.W. #304 7920 Norfolk Avenue                    Washington, D.C. 20008 Bethesda, MD 20814 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 Commission U.S. Nuclear Regulatory Commission P. O. Box 910                          Washington, DC 20555 Bay City, TX 77414 Charles Bechhoefer, Esquire M. D. Schwarz, Jr. , Esquire            Chairman, Atomic Safety & Licensing Board Baker & Botts                          U.S. Nuclear Regulatory Commission One Shell Plaza                        Washington, DC 20555 Houston, TX 77002 Dr. James C. Lanib, III J. R. Newman, Esquire                   313 Woodhaven Road Newman & Holtzinger, P.C.              Chapel Hill, NC 27514 1615 L Street N.W.
Washington, DC 20036                    Judge-Frederick J. Shon Atomic Safety and Licensing Board Director, Office of Inspection         U. S. Nuclear Regulatory Commission and Enforcement                     Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555                    Mr. Ray Goldstein, Esquire 1001 Vaughn Building E. R. Brooks /R. L. Range              807 Brazos Central Power & Light Company           Austin, TX 78701 P. O. Box 2121 Corpus Christi, TX. 78403               Citizens for Equitable Utilities, Inc.
c/o Ms. Peggy Buchorn H. L. Peterson/G. Pokorny               Route 1, Box 1684 City of Austin                          Brazoria, TX 77422 P. O. Box 1088 Austin, TX 78767                        Docketing & Service Section Office of the Secretary J. B. Poston/A. vonPosenberg            U.S. Nuclear Regulatory Commission City Public Service Board               Washington, DC 20555 P. 0. Box 1771 San Antonio, TX 78296 W2/NRC2/o                                                  Revised 5/22/85

            .                                                       Attachment 1 l                                                                    ST-HL-AE-1363         '
l                                                                    File No.: G2.4, M22.3 Page 1 of 3
                                                                                           ?
Sout? Texas Project buits 1 & 2 50-198/8506-01 50-499/8506-01 I. Statement of Violation                                                   i During an NRC Inspection conducted April 15 through May 24, 1985, a violation of NRC requirements was identified. The violation as described in NRC Inspection Report 50-498/8506-01,50-499/8506-01 is provided below:                                                      '
                          " Criterion V of Appendix B to 10 CFR Part 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 (Quality Assurance Plan Description) for South Texas Project.
Procedure CSP-6, Rev. 2, dated March 7, 1985, requires that      ,
hangers be constructed in accordance with installation           <
documents and to present hangers in acceptable condition prior to quality control inspector's review and that the HVAC craft supervisor assures conformance to the installation documents,
                                        ~
and assure inspections are performed.
Contrary to the above, the NRC inspector visually inspected Support 1-5-0036-S022. The records indicate that the bolts were torqued. Visual inspection indicated that these bolts       !
were loose.
This is a Severity Level-IV violation (10 CFR Part 2 SupplementII)(50/491-8506-01)."
II. Reply Thesubjectsupport(1-5-0036050002) is a nonsefety-related Class 7 (II/I) component which does not require inspection by Quality Control (QC)'. Field engineering had previously accepted and recorded it with the- bolts properly torqued but it was later found by the NRC inspector to have loose bolts. .The reason for this condition is believed to be unauthorized work by craft personnel after final inspection. As a' result of this Notice of Violation, Ebasco and Bechtel QA performed additional surveillances on Class 7 installations. No deficiencies were identified.
Investigations also revealed that the Ebasco procedure does not address or document " modification or removal" of Class 7 installations that have been previously inspected and accepted by field engineering.
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Attachment 1 ST-HL-AE-1363 File No.: G2.4, M22.3 Page 2 of 3 III. Corrective Actions Taken or to be Taken As provided in the requirements of ASP-16, Deficiency Report (DR)
M-0576 was issued to track the resolution of the condition.
Retorquing of the bolts has been performed.
IV. Steps Taken or-To Be Taken to Avoid Further Violations Applicable Ebasco procedures for Class 7 installations will be i                   revised to include requirements to control the modifications and/or removal of items that have been inspected and accepted by inspection personnel. Appropriate personnel will be reinstructed in the requirements of these procedures once they are revised.
This is scheduled.for completion by October 15, 1985.
Although surveillances performed by Bechtel and Ebasco indicate that the condition cited was an isolated occurrence in Class 7 installations', there had, however, been instances of " unauthorized work" in safety-related applications that were_ documented in project deficiency reports prior to this Notice of Violation. As a result, a reinstruction of Ebasco construction personnel had already been implemented by means of the " Quality Talk" program.
Ihe following points were emphasized to craft personnel during this reinstruction:
o     When items have been_ inspected no modifications or removal may be made without first notifying QC, Safety-related items that have been made at.the Ebasco On-site Fabrication Shop a'nd QC inspected before release
 ;                               are considered to be final inspected. Items bought from other manufacturers are also considered to be final inspected.
4 o     QC is to be notified by the use of Modification /
Removal Control Form. This form must be filled out by.co~nstruction personnel and signed by the appropriate QC supervisor before any modification or removal may take place.
c     Typical examples of work that requires use of the 4                                Modification / Removal Control Form, cited during the reinstruction, include removal of a vendor or shop weld, removal and relocation of Nelson studs, taking apart bolted connections or removing a. nut etc., and complete removal of an installed and inspected item.
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Attachment 1 ST-HL-AE-1363 File No.: G2.4, M22.3 Page 3 of 3 Ebasco Construction also issued a memo to craft personnel which re-emphasized the policy that all STP work is performed by procedure with written authoriz'ations, and that all items or components which are installed, inspected and and accepted, are not to be removed or altered without written authorization. It also directs craft to contact supervision for questions about their work.
V. Date When Full Compliance Will Be Achieved October 15, 1985 l
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