ML20214E735

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-498/86-23

ML20214E735
Person / Time
Site:	South Texas
Issue date:	11/17/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8611250077
Download: ML20214E735 (2)

See also: IR 05000498/1986023

Text

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NOV 171986

In Reply Refer To:

Dockets: 50-498/86-23

Houston Lighting & Power Company

ATTN: J. H. Goldberg, Group Vice

President, Nuclear

P. O. Box 1700

Houston, Texas 77001

Gentlemen:

Thank you for your letter of November 3,1986, in response to our letter

and Notice of Violation dated October 8,1986. We have reviewed your reply and

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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,

OrfJ.ina! Sknod By

J. E. Gagliardo

J. E. Gagliardo, Chief

Reactor Projects Branch

cc:

Houston Lighting & Power Company

ATTN: M. Wisenberg, M:,1ager,

Nuclear Licensing

P. O. Box 1700

Houston, Texas 77001

,

Brian Berwick, Esquire

Asst. Attorney General

Environmental Protection Division ,

P. O. Box 12548, Capitol Station

Austin, Texas 78711

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Houston Lighting & Power Company -2-

Lanny Alan Sinkin

Citizens Concerned About Nuclear

Power, Inc.

Christic Institute

1324 North Capitol Street

Washington, D.C. 20002

Charles Bechhoefer, Esquire

Chairman, Atomic Safety & Licensing

Board

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Dr. James C. Lamb, III

313 Woodhaven Road

Chapel Hill, North Carolina 27514

Frederick J. Shon

Administrative Law Judge

Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Alvin H. Gutterman

Newman & Holtzinger, P.C.

1615 L St., N.W., Suite 1000

Washington, D.C. 20036

Texas Radiation Control Program Director

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R. D. Martin, RA RRI-CONST.

SectionChief(RPB/C) R&SPB

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R. Pirfo, ELD R. G. Taylor, RPB/C

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November 3,1986

ST-HL-AE-1747

File No.: G2.4

Mr. Robert D. Martin J ,i ]hNhh.[l?.di

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Regional Administrator, Region IV tl

U. S. Nuclear Regulatory Commission I l NOV 6l986 ,

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611 Ryan Plaza Drive, Suite 1000 W b

Arlington, Texas 76011 -

South Texas Project

Units 162

Docket Nos. STN 50-498, STN 50-499

Response to Notice of Violation 8623 02

Dear Mr. Martin:

Houston Lighting & Power Company has reviewed Notice of Violation

50 498/8623-02 dated October 8, 1986 an( submits the attached response

pursuant to 10CFR 2.201.

If you should have any questions on this matter, please contact

Mr. S.M. Ilead at (512) 972-8392.

Very truly yours,

J. H. Goldberg

Group Vice President, Nuclear

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Attachment: Response to Notice of Violation 8623-02

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ST-HL-AE-1747

Ilouston Lighting & Power Company File No.: G2.4

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Page 2

cc:

Fugh L. Thompson, Jr. , Director J. B. Poston/A, vonRosenberg

Division of PWR Licensing - A City Public Service Board

Office of Nuclear Reactor Regulation P.O. Box 1771

U.S. Nuclear Regulatory Commission San Antonio, TX 78296

Washington, DC 20555

Brian E. Berwick, Esquire

N. Prasad Kadambi, Project Manager Assistant Attorney General for

U.S. Nuclear Regulatory Commission the State of Texas

7920 Norfolk Avenue P.O. Box 12548, capitol Station

Bethesda, MD 20814 Austin, TX 78711

Claude E. Johnson Lanny A. Sinkin

Senior Resident Inspector /STP Christic Institute

c/o U.S. Nuclear Regulatory 1324 North Capitol Street

Commission Washington, D.C. 20002

P.O. Box 910

Bay City, TX 77414

Oreste R. Pirfo, Esquire

Hearing Attorney

M.D. Schwarz , J r. , Esquire Office of the Executive Legal Director

Baker & Botts U.S. Nuclear Regulatory Commission

One Shell Plaza Washington, DC 20555

llouston, TX 77002

Citizens for Equitable Utilities, Inc.

J.R. Newman, Esquire e/o Ms. Peggy Buchorn

Newman & IIoltzinger, P.C. Route 1, Box 1684

1615 L Street, N.W. Brazoria, TX 77422

Washington, DC 20036

Docketing & Service Section

Director, Office of Inspection Office of the Secretary

and Enforcement U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission Washington, DC 20555

Washington, DC 20555 (3 Copies)

T.V. Shockley/R.L. Range Advisory Committee on Reactor Safeguards

Central Power & Light Company U.S. Nuclear Regulatory Commission

P.O. Box 2121 1717 11 Street

Corpus Christi, TX 70403 Washington, DC 20555

A. Backus/J. E. Malaski

City of Austin

P.O. Box 1088

Austin, TX 78767

Revised 10/09/86

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ST-HL AE-1747

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File No.: C2.4

Page 1 of 4

South Texas Project '

Units 1 & 2

Docket Nos. STN 50-498, STN 50-499

Response to Notice of Violation 8623-02

I. Statement of Violation

Criteria V of Appendix B to 10 CFR Part 50, requires activities affecting

quality be prescribed by and accomplished in accordance with appropriate

instructions, procedures, or drawings. This requirement is amplified by

the approved QAPD for South Texas Project. The following are examples of

failures to meet this requirement.

1. SSP-9.0, Revision 4, paragraph 5.2.7.3 states, "that all work on

permanent or temporary supports which are released for test shall

require a Startup Work Request (SWR) before any work can be

performed."

Contrary to the above, construction craft removed the main steam

piping temporary supports in Isolation Valve cubical (IVC) A and C

without a SWR which resulted in an overload condition of the main

steam line.

2. Specification SL340JS1002, Revision 10, paragraph 5.4.4.5 states, in

part, that deviations in the actual cold position are permitted to

account for slight imbalance. The constructor shall check / verify to

assure that this deviation will not result in bottoming out or

topping out of the spring hangers due to thermal or seismic

movements of the pipe.

Contrary to the above, construction craft did not check / verify the

main steam (MS) line in Unit 1 IVC A and C after hydrostatic testing

resulting in the bottoming out of spring hangers MS1001-HL5013 and

MS1003-HL5018.

3. Specification 5L340JS1002, Revision 10, paragraph 5.4.4.7 states

" travel stops in variable springs may be removed, as directed by

engineering, to facilitate system testing."

l Contrary to the above, travel stops in variable spring hangers

l MS1001-HL5013 and MS1003 HL5018 were removed without approval from

engineering.

This is a Severity Level IV violation. (10CFR Part 2, Supplement 1.E.)

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(498/8623-02)

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Page 2 of 4

II. Reason for Violation

The root cause of this Violation has been determined to be a lack of

attention by construction personnel to applicable project requirements for

removal of temporary supports and travel stops, verification of spring hangers

for bottoming out or topping out conditions, and a misinterpretation by

Quality Control (QC) personnel of procedural requirements for removal of

travel stops. System testing may require removal of some travel stops, as

directed by Engineering in the Engineering Pipe and Pipe Supports Evaluation

Sheets (also called Hanger Adequacy Letters); however, verification of the

status of travel stops prior to hydrostatic test was not performed. QC

assumed that the issuance of the Adequacy Letter by Engineering provided the

necessary verification.

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III. Corrective Action Taken And Results Achieved

An investigation of the situation was performed and the following

documents were issued to assess and correct the problem: (i)

Nonconformance Reports (NCR's) CS-03998, CS-03999, CS 04008 and CS-04039

were prepared to document the nonconforming conditions, (ii) Stop Work

Notice 86-03 was issued to prevent any further unauthorized work on the

affected Main Steam Lines within the Unit 1 IVC (The Stop Work Notice was

lifted after completing the investigation), (iii) Engineering Problem

Investigation Report 86-5029 was issued to evaluate the reported

condition and determine the necessary corrective action, (iv) Deficiency

Evaluation Report 86-037 was issued to evaluate the condition for

potential reportability pursuant to 10CFR50.55(e) and 10CFR part 21

requirements.

To assess the overall status of temporary and permanent supports, a walk-

down was performed on other piping systems containing a total of one

hundred and sixteen (116) permanent and temporary supports. These

supports were found to be installed in accordance with the project

requirements. Supports with spring hangers were inspected to assure that

the travel stops were in place as required. Additionally, it was

, verified that permanent and temporary supports were properly tagged.

Craft and field engineering personnel were retrained on the requirements

for the removal of travel stops and temporary supports. The training was

based on the controls in place at the time this problem occurred, and

stressed that temporary supports and travel stops must not be removed

without Engineering approval.

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Temporary supports for the main steam lines were immediately provided to

preclude further pipe movement. In addition, an analysis of the stresses

imposed on the permanent plant supports, piping and associated structures

has been performed. Analysis has shown that the deficiency did not

result in overstress of the main steam lines, permanent plant supports,

or associated structures. NCR dispositions are based on the results of

the stress analysis.

IV. Corrective Steps Which Have Been Taken To Prevent Recurrence

In addition to the above, the following actions have been taken to

prevent recurrence of the problem:

o Specification SL340JS1002 " Pipe Support Field Fabrication and

Installation", for controls of permanent plant hangers, temporary

supports and spring hanger travel stop installation and removal was

reviewed and found to be adequate. However, the specification has

been clarified to better define the project requirements related to

travel stops,

o Standard Site Procedure SSP 2 " Project Generic Pressure Test

Procedure", was reviewed to determine if appropriate controls were

specified for work performed on spring hanger travel stops and

essential supports required for hydrostatic test and was found to be

adequate. However, SSP-2 was revised to clatify its intent to avoid

any possible misinterpretation of project requirements regarding

removal of travel ntops. The revision also included requirements

for QC to verify, during the walkdown prior to hydrostatic test,

that spring hanger travel stops are either in place or removed in

accordance with Engineering direction given in the Hanger Adequacy

Letter. In addition, Field Engineering will verify that spring

hangers are not bottomed or topped out.

o Standard Site Procedure SSP 9 " Pipe Support Installation" was

reviewed to determine if appropriate controls were specified for

temporary and permanent support installation and was found to be

adequate. However, SSP-9 has been revised to clarify the

requirements for Design Engineering approval of work on temporary or

permanent supports after release for test and to clarify the

requiremonts that permanent supports be installed and that Field

Engineering approval be obtained prior to the remeval of temporary

supports. In addition, the revision added the requirement for QC to

verify that spring hanger travel stops have been removed as required

for system balancing and that documentation to support balancing is

available.

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o Standard Site Procedure SSP-36 " Construction Work Package" was also

revised to include a requirement for Field Engineering to approve

the removal of a temporary support after its associated permanent

support is installed. This will ensure that a permanent support is

functional prior to the removal of the temporary support.

Appropriate Construction and QC personnel have received training on the

requirements of the revised procedures.

V Date of Full Compliance

STP is in full compliance at this time.

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