IR 05000498/1985021

Discusses Insp Repts 50-498/85-21,50-499/85-19,50-498/85-24, 50-499/85-21,50-498/86-12 & 50-499/86-12 on 851021-1122, 851201-860131 & 860414-18,respectively & Forwards Notice of Violation.Concerns Expressed Re Insp Deficiencies

ML20206P070
Person / Time
Site:	South Texas
Issue date:	08/20/1986
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
Shared Package
ML20206P074	List: ML20206P070 ML20206P080
References
EA-86-010, EA-86-10, NUDOCS 8608270086
Download: ML20206P070 (4)

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AUG 9 01985 Docket Nos. 50-498 and 50-499 License Nos. CPPR-128 and CPPR-129 -

EA 86-10 Houston Lighting & Power Company ATTN: J. H. Goldberg Group Vice President P.O. Box 1700 Houston, Texas 77001 ,

Gentlemen:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-498/85-21 AND 50-499/85-19, 50-498/85-24 AND 50-499/85-21, 50-498/86-12 AND 50-499/86-12)

This refers to the inspections at the South Texas Project (STP) near Bay City, Texas conducted during the periods of October 21 - November 22, 1985, December 1,1985 - January 31, 1986, and April 14 - April 18, 1986. These

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inspections were primarily conducted by the IE Construction Appraisal Team (CAT) with followup by Region IV personnel. A number of Potential Enforcement Actions (PEAS)-were identified during the inspections. The findings were discussed in an enforcement conference held on March 27, 1986, in the Region IV office in Arlington, Texa Your letter of January 10, 1986, provided your initial corrective actions in response to the CAT inspection. In your letter of April 2, 1986, you responded to the specifics of the CAT inspection report and requested that the NRC reconsider certain items. In our inspection of April 14-18, 1986, documented in Inspection Report 50-498/86-12; 50-499/86-12, we evaluated your initial corrective actions and based on our followup inspection and on new information provided we withdrew PEAS 4 and Portions of other PEAS were also withdrawn or modified as described in the report. Although we have withdrawn a portion of the CAT findings, the remaining findings involve violations which indicate that significant weaknesses in your program existed at the tine of the CAT inspcetio Violation 1.A in the enclosed Notice of Violation involves several examples of deficiencies in your contractor's inspection program and represents a significant l weakness in your construction quality control program. CompoMnts and structures which had been already in?pected and accepted by quality control personnel were found not to meet specified requirements. The nature of the deficiencies indicates that personnel were not paying adequate attention to detail, although there r.re also indications that they were not being provided adequate guidance on how to perform the inspections. He understand that essentially all of the deficient installations were accomplished by your present contractor and inspected by the contrsctor's quality control organire. tio CERTIFIED MAIL RETURN RECEIPT REQUESTED k

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Houston Lighting & Power Company -2-Violation I.B in the Notice involves several examples of the failure of design review measures to assure the adequacy of design and indicates that your engineers were not paying sufficient attention to detail during the design /

design change process or during design reviews. The failure of these design review measures resulted in components being installed not in accordance with the Architect / Engineer's or vendor's instruction Violation I.C in the Notice involves several examples of the failure of measures to assure that rtrehased equipment met the procurement documents. This equipment had been inspected by the vendor, accepted by the licensee, and installed in the plant without being identified as not meeting procurement documents until reviewed by the NRC CA Violations I.A, I.B, and I.C collectively reflect a significant breakdown in your quality assurance program because they involve multiple examples of deficient construction that had not been identified by your quality assurance program and components were installed which did not meet design or vendor requirements. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1986), Violations 1.A,'

I.B, and I.C described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem. Normally, a civil penalty is considered for a Severity Level III violation er problem. However, after

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consultation with the Director, Office of Inspection and Enforcement, I have decided that a civil penalty will not be proposed in this case because of your overall good perforrance in the general area of concern for the past several years and your prompt and extensive corrective actions once these violations were identified. The corrective actions included: significantly increasing Houston Lighting & Power Company's management presence on site; realigning of contractor organizations; reassigning cf key project personnel; increasing training of construction personnal; and improving the system for holding supervisors responsible for work complete Violation II.A involves the installation of fasteners which did not have proper markings. Although the bolting material installed may have met strength and material requireuents, without markings or a material control program, the NRC could not determine whether the bolting material could satisfy its intended application. Violation II.B involves the failure to promptly issue a non-conformance report and apply hold tags after nonconforming conditions were identified on instrument nozzle piping. These violations involve deficiencies

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of a less serious nature than in Violations I.A-C but are of more than minor concern and require additional management attention. Therefore, these violations have been categorized in the aggregate as a Severity Level IV proble You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional l actions you plan to prevent recurrence. Although you have;already provided l your preliminary response and corrective actions to the specific CAT findings as ;

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Houston Lighting & Power Company -3-identified in the CAT report dated February 5, 1986, you should re-evaluate your i response in light of the discussion presented in this letter and-the enclosed ,

Notice. Please also provide information on how you intend to verify that your corrective actions have improved the overall effectiveness of inspections and on how you plan to assure yourself that the inspection deficiencies identified are not indicative of potential construction deficiencies in the as-built plant After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is neces-sory to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, Original signed by: -

Robert D. Martin Robert D. Martin Regional Administrator l

Enclosure:

Notice of Violation ,

cc:

Texas Radiation Control Program Director

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DISTRIBUTION bec w/ encl:

PDR SECY CA JMTaylor, IE RStarostecki, IE JAxelrad, IE HWong, IE RHeishman, IE ,

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Enforcement Officers RI, RII, RIII, RV LCobb, IE -

JCrooks, AEOD BHayes, 01 SConnelly, OIA DNussbaumer, OSP -

IE:ES File IE:EA File DCS RIV Distribution:

Regional Administrator, RMartin Division Director, DRSP Branch Chief, RPB Section Chief, RPSC DPowers Inspector (2 copies)

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