ML20212E743

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/86-31 & 50-499/86-31

ML20212E743
Person / Time
Site:	South Texas
Issue date:	12/31/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8701050430
Download: ML20212E743 (2)

See also: IR 05000498/1986031

Text

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f; .. DEC 311988

,In Reply Refer To:

Dockets: 50-498/86-31

50-499/86-31

Houston Lighting & Power Company

ATTN: J. H. Goldberg, Group Vice

President, Nuclear

P, O. Box 1700

Houtton. Texas 77001

Gentlemen:

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Thank you for your letter of Noveber 25, 1986, in response to our letter and

Notice of Violation dated October 22, 1986. We have res iewed your reply and 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

detennine that full compliance has been achieved and will be maintained.

Sincerely,

'w.+u' c; rcri By:

q.t.'vt"

J. E. Gagliardo, Chief

Reactor Projects Granch

cc:

Houston Lighting & Power Company

ATTN: M. Wisenberg, Manager,

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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8701050430 861231

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PDR ADOCK 05000498 \

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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

Chairnen, 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

bec to DMB (IE01)

bec distrib. by RIV:

RPB Project Inspectors (2)

RRI-0PS R. D. Martin, RA

RRI-CONST. SectionChief(RPB/C)

R&SPB MIS System

RIV File D. Weiss, RM/ALF

RSTS Operator R. Pirfo, ELD

RSB

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The Light

mmPuy 1,eos,em ti,s ieg & Pe e, iso. nex ivoo iieos,ee. rexes 7200> <2i3> 22s.92ii

November 25, 1986

ST-HL-AE-1800

File No.: G2.4

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Mr. Robert D. Martin

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Regional Administrator, Region IV

U. S. 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 8631-01/8631-01

Dear Mr. Martin:

Houston Lighting and Power Company (HL&P) has reviewed Notice of

Violation 50-498/8631-01, 50-499/8631-01 dated October 22, 1986, and submits

the attached response pursuant to 10CFR2.201. The housekeeping corrective

actions to prevent recurrence indicated herein also address the concerns

raised by USNRC Region IV Inspector J. E. Bess during his recent inspection.

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

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

Very truly yours,

sY.

J. H. Goldberg

Group Vice President, Nuclear

WPE/hg

Attachment: Response to Notice of Violation (498/499-8631-01)

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ST-HL-AE-1800

Houston Lighting & Power Company ile No.: C2.4

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cc:

Hugh L. Thompson, Jr. , Director T.V. Shockley/R.L. Range

Division of PWR Licensing - A Central Power & Light Company

Office of Nuclear Reactor Regulation P.O. Box 2121

U.S. Nuclear Regulatory Commission Corpus Christi, TX 78403 >

Washington, DC 20555

O. Backus/J. E. Malaski

Robert D. Martin' City of Austin

Regional Administrator, Region IV P.O. Box 1088

Nuclear Regulatory Commission Austin, TX 78767

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011 J. B. Poston/A. vonRosenberg

City Public Service Board

N. Prasad Yadambi, Project Manager P.O. Box 1771

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

7920 Norfolk Avenue

Bethesda, MD 20814 Brian E. Berwick, Esquire ,

Assistant Attorney General for

Dan R. Carpenter the State of Texas

Senior Resident Inspector / Operations P.O. Box 12548, Capitol Station

c/o U.S. Nuclear Regulatory Austin, TX 78711-

Commission

P.O. Box 910 Lanny A. Sinkin

Bay City, TX 77414 Christic Institute

1324 North Capitol Street

Claude E. Johnson Washington, D.C. 20002

Senior Resident Inspector /STP

c/o U.S. Nuclear Regulatory Oreste R. Pirfo, Esquire

Commission Hearing Attorney

P.O. Box 910 Office of the Executive Legal Director

Bay City, TX 77414 U.S. Nuclear Regulatory Commission

Washington, DC 20555

M.D. Schwarz , Jr. , - Esquire

Baker & Botts Citizens for Equitable Utilities, Inc.

One Shell Plaza e/o Ms. Peggy Buchorn

Houston, TX 77002 Route 1, Box 1684

Brazoria, TX 77422

J.R. Newman, Esquire

Newman &'holtzinger, P.C. Docketing & Service Section

1615 L Street, N.W. Office of the Secretary

Washington, DC 20036 U.S. Nuclear Regulatory Commission

Washington, DC 20555

Director, Office of Inspection (3 Copies)

and Enforcement

U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards

Washington, DC 20555 U.S. Nuclear Regulatory Commission

1717 H Street

Washington, DC 20555

Revised 11/12/86

1A/NRC/ab

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Attachment

. ST-HL-AE-1800

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File No.: C2.4

Page 1 of 3

South Texas Project

Units 1 & 2

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

Response to Notice of Violation 8631 01/8631-01

I. Statement of the Violation

During an NRC inspection conducted on August 30 through October 3, 1986,

a violation of NRC requirements was identified. The violation involved

the component cooling water pump room. In accordance with the "Ceneral

Statement of Policy and Procedure for NRC Enforcement Actions,"

10CFR Part 2, Appendix C (1986), the violation is listed below:

" Failure to Follow Inplace Storage Requirements

Criterion XIII of Appendix B to 10CFR50, states, in part, that

measures shall be established to control the handling, storage, and

preservation of material and equipment to prevent damage or

deterioration.

This requirement is amplified by Section 13 of the HL&P Quality

Assurance Program which requires that storage requirements be

promulgated in procedures and specifications to preclude damage and

deterioration.

Bechtel specification 5A300GS1002, Revision 8, paragraph 3.3D

requires in-place protection to minimize damage or degradation of

quality.

Contrary to the above, the "B" Component Cooling Water Pump, motor,

and other room accessories have not been adequately protected from

the overhead installation of fireproofing insulation resulting in a

deteriorating condition.

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This is a Severity Level IV violation. (Supplement I. E)

(498/8631-01)"

II. Reason for Violation

The "B" CCW Pump, motor, and other accessories in the room were

inadequately protected due to poor coordination of construction and

start-up activities in the room. Several Project organizations were

performing activities around the equipment. These activities restricted

the installation of protective plastic over portions of the equipment.

Fireproofing was originally scheduled to be accomplished prior to

start-up activities. This work was delayed and was eventually performed

under a work release which was not coordinated to reflect the new status

of the room.

HL&P has determined that, even though there was a violation of in-place

protection requirements, the deficiency did not adversely affect the

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equipment.

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Attachment

ST-HL-AE 1800

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File No.: C2.4

Page 2 of 3

III. Corrective Actions Taken and Results Achieved

The fireproofing contractor has performed a thorough clean-up of the

area. This clean-up was in-progress at the time the violation was

identified. The contractor also installed additional scaffolding and

protective plastic over the component cooling water pumps, eliminating

the uncovered areas. HL&P has determined that the additional measures

were satisfactory.

Ebasco Construction issued a Standard Deficiency Report (SDR) to address

similar deficiencies in the area which were observed subsequent to the

NRC inspection. The area was cleaned to remove all debris from the CCW

pumps. Quality Assurance / Control (QA/QC) and Construction inspections of

surrounding areas and Unit 1 buildings have verified the overall in-place

protection of Unit 1 equipment to be satisfactory. Equipment in the

inspected areas was adequately protected from construction related

activities.

IV. Corrective Steps Which Have Been Taken to Prevent Recurrence

The following additional actions have been taken:

o A program has been implemented to enhance plant clean up efforts, to

minimize possible equipment damage, and to ensure housekeeping

levels are acceptable for commercial operation. Actions included in

this program are

o Dedicated construction superintendents have been assigned whose

sole function is to ensure clean-up of the plant.

o Startup has assigned personnel, by area, that are responsible

for coordinating cleanliness activities with construction.

~ o Permanent plant equipment will be cleaned (as needed) on a

daily basis,

o Ebasco management has discussed this issue with the Discipline

Managers in meetings, emphasizing their responsibilities in the

areas of in-place protection and housekeeping. These discussions

re-emphasized the matrix developed to identify individuals

responsible for maintaining areas and equipment in compliance with

site requirements. This matrix was developed to improve overall

housekeeping and in-place protection.

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File No.: G2.4

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o QC' personnel responsible for surveillance of housekeeping and

in-place protection of equipment have been given a copy of the

matrix to assist in the resolution of problems. Ebasco has

designated a manager to administer this program. He is to be the

. central contact for the resolution of concerns if action by the

primary contact is not "qdequrte.

o A program has been established to address housekeeping and in-place

protection concerns which require swift resolution to prevent the

, degradation of equipment.

'o .Bechtel management has issued a directive to all appropriate

organizations, including contractors, directing improvement on

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performance and coordination of activities to prevent additional

problems. Attached to..this directive are the matrix of Constructor

individuals responsible for maintaining housekeeping and in-place

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protection in plant . areas and the list of personnel from other

'ur6anizationa,.(Sta'rtup, Bechtel Contracts), responsible to

coordinate rasolution of problems identified.

o A Quality Talk has been given.to Construction personnel emphasizing

the need to comply with the requirements for in-place protection and

l housekeeping.

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In conjunction with the Quall'ty Talk, an article was included in the

site newsletter to improve o terall jobsite familiarization with this

situation.

o HL&P executive management has. admonished its Operations Department

to pe'esonally oversee residual construction work activities

affecting system's, equipment, or facilities turned over to HL&P to

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assure that the work is carried out with proper regard for the

physical protection of such systems, equipment, or facilities.

4 We believe the abov'e~9tions a provide assurance that the project can be

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maintained in a clean. condition and that appropriate and timely actions

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are tiken should s,

future situations result in a deficient condition.

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V. Date of Full Compliance -

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The project is pr6sently'in full compliance.

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