ML20236K592

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/87-27 & 50-499/87-27

ML20236K592
Person / Time
Site:	South Texas
Issue date:	08/04/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8708070179
Download: ML20236K592 (2)

See also: IR 05000498/1987027

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In Reply Refer To:

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-Dockets:

50-498/87-27-

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50-499/87-27

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Houston Lighting & Power Company

ATTN:

J. H. Goldberg, Group Vice

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President, Nuclear

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.P. 0.' Box 1700

Houston, Texas

77001-

' Gentlemen:

Thank you for your letter of July 22, 1987, in response to our letter and

Notice of Violation dated June 22, 1987. We have reviewed your reply and find

it responsive to the concerns raised in our Notice of Violation. We will

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review the implementation of your corrective actions during a future

inspection to determine that full compliance has been achieved and will be

maintained.

Sincerely.

Uridad

R. E. HALU

J. E. Gagliardo, Chief'

Reactor Projects Branch

cc:

.

. Houston Lighting & Power Company

ATTN:

M. Wisenberg, Manager,

Nuclear Licensing

P. O. Box 1700

Houston, Texas

77001

Houston Lighting & Power Company

ATTN:

Gerald E. Vaughn, Vice President

Nuclear Operations

P. O. Box 1700

Houston, Texas

77001

Texas Radiation Control Program Director

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JUL 2 71987

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July 22,1987

ST-HL-AE-2308

File No.: C2.4

10CFR2.201

U. S. Nuclear Regulatory Commission

Attention:

Document Control Desk

Washington, DC

20555

South Texas Project

Units 1 and 2

Docket Nos. STN 50-498. STN 50 499

Response to Notices of Violation 87 27-02 and 87 27 03

Houston Lighting & Power Company has reviewed Notices of Violation

87-27-02 and 87-27-03 dated June 22, 1987, and submits the attached response

pursuant to 10CFR2.201.

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

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

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J. H. Coldberg

Group Vice President, Nuclear

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Attachments: Response to Notices of Violation

87-27-02 and 87-27-03

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A Divisien of Houston Industries Incorporated

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ST-HL-AE-2308

Houston Lighting & Power Company

File No.. G2.4

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Page 2

Cc:

Regional Administrator, Region IV

M.B. Lee /J.E. Malaski

Nuclear Regulatory Commission

City of Austin

611 Ryan Plaza Drive, Suite 1000

P.O. Box 1088

Arlington, TX 76011

Austin, TX 78767-8814

N. Prasad Kadambi, Project Manager

A. von Rosenberg/M.T. Hardt

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U.S. Nuclear Regulatory Commission

City Public Service Board

7920 Norfolk Avenue

P.O. Box 1771

Bethesda, KD 20814

San Antonio, TX 78296

Robert L. Perch, Project Manager

Advisory Committee on Reactor Safeguards

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

7920 Norfolk Avenue

1717 H Street

Bethesda, MD 20814

Washington, DC 20555

Dan R. Carpenter

- Senior Resident Inspector / Operations

e/o U.S. Nuclear Regulatory

Commission

P.O. Box 910

Bay City, TX 77414

Claude E. Johnson

Senior Resident Inspector / Construction

c/o U.S. Nuclear Regulatory

Commission

P.O. Box 910

Bay City, TX 77414

M.D. Schwarz , Jr. , Esquire

Baker 6 Botts

One Shell Plaza

Houston, TX 77002

J.R. Newman, Esquire

Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036

R.L. Range /R.P. Verret

Central Power & Light Company

P. O. Box 2121

Corpus Christi, TX 78403

L4/NRC/cb/hg-0

Revised 6/23/87

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Attachment

ST-HL-AE-2308

File No.

C2.4

Page 1 of 4

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South Texas Project

Units 1 and 2

Docket Nos. STN 50 498, STN 50-499

Response to Notices of Violation 87-27-02 and 87-27 03

NOTICE OF VIOLATION 87-27-02

1. STATEMENT OF VIOLATION

" Criterion VI of Appendix B to 10CFR50 requires that measures be

established to control the issuance of documents such as drawings,

including changes thereto, and that 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,

" Contrary to the above, a design change notice (Brovn & Root DCN No.

1-S-1600-1) issued in 1980, but never implemented, was erroneously

incorporated into Bechtel design drawing No. 3C01-9-S-1600 and Bechtel

calculation No. 20011SC045, "RHR Pump Support Pedestal." As a result of

this erroneous incorporation, both the Bechtel drawing and calculation

indier.ted a 1/2-inch weld on the column to base plate connection while

the actual as-built condition was a 5/16-inch weld."

II. REASON FOR VIOLATION

When Brown & Root issued the design change for the RHR pump supports,

they made a drafting error in that they failed to indicate that an

increase (from 5/16 to 1/2-inch) in the weld size of vendor welds on the

RHR pump support columns would require field rework. Apparently, B&R

failed to recognize that the vendor had previously fabricated the weld

and delivered the support to site.

Because the drawing did not call out

the field work to the vendor weld, B&R Construction did not modify the

weld.

During turn over of documents from B&R to Bechtel, Bechtel revised the

design drawing, in number only, to be 3C019S1600, Revision 0.

Bechtel

did not detect the discrepant condition because the normal evaluation of

B&R design drawings and calculations emphasized consistency between

design documents and verification of their technical adequacy.

The

interrelationship between receipt of materials and subsequent design

changes to the materials during the B&R era was not identified as an area

of concern prior to the transition from B&R to Bechtel.

Therefore,

additional scrutiny in that area was not procedurally imposed during the

transition phase.

Bechtel's technical review and subsequent revision of B&R's calculation

determined that the increase in weld size was unnecessary.

Cross-bracing

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ST-HL-AE-2308

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Page 2 of 4

was added to resolve other desi n concerns about the supports. As such,

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the 1/2-inch weld was not reverifiad prior to issuance of the Bechtel

revision to the calculation.

Due to the circumstances surrounding this discrepancy and the chronology

involved, STP has determined that this discrepancy represents an isolated

case of design error.

III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

STP performed a reinspection of the affected RHR pump supports to ensure

tha't the weld size was indeed 5/16-inch (as identified in the NRC

inspection). The reinspection showed that, within specification

tolerances, the weld was a S/16-inch weld.

The design calculation

(Bechtel calculation no. SC045-4B, Revision 7) was revised to

specifically document the conclusion that the increased weld size was

unnecessary.

The dis >

nt drawing (3C019S1600, Revision 8) was reviscd

to show the appropriat.

.se weld.

IV. CORRECTIVE STEPS TAKEN TO PREVENT RECURRENCE

Since this is an isolated case of a Brown & Root drafting error, no

actions to prevent recurrence are necessary.

V. DATE OF FULL COMPLI ANCE

STP is in full compliance at this time.

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Attachment

ST-HL-AE-2308

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File No.: G2.4

Page 3 of 4

NOTICE OF VIOLATION 87-27-03

I. STATEMENT OF VIOLATION

" Criterion V of Appendix B to 10CFR50 requires that activities affecting

quality be prescribed by documented instructions or procedures, and shall

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be accomplished in accordance with these procedures.

Bechtel

Construction Specific.ation No. 3A010SS0030, Revision 8, " Specification

for Erection of Structural Steel and Miscellaneous Steel," Section

7.1.1.4, requires that high-strength bolts be installed in accordance

with the American Institute of Steel Construction (AISC) " Specification

for Structural Joints Using ASTM A325 or A490-Bolts." Section 5 of the

AISC specification requires that fasteners be tightened to provide, when

all fasteners in the joint are tight, at least the minimum tension of

39,000 pounds'for 7/8-inch diameter A325 bolts.

" Contrary to the above, the NRC inspector independently measured the

tension for 12 randomly selected 7/8 inch diameter A325 bolts on each of

the three. Residual Heat Removal (RHR) pump support structures and.found

that the tension was less than the required value of 39,000 pounds for

one bolt on RHR pump A and for six bolts on RHR pump C.

All three RER

pump support structures had been inspected by Quality Control."

II. REASON FOR VIOLATION

STP has determined that an inappropriate standard site procedure (SSP)

was used to install the RHR pump supports cross-braces.

SSP-52,

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" Installation Assembly and Disassembly of Permanent Mechanical Plant

Equipment," was used to install the bolted connections as opposed to

SSP-11

" Fabrication, Erection, and Bolt-up of Structural Steel." SSP 11

provides appropriate inspection and installation instructions to ensure

that structural bolted connections are installed correctly.

SSP-52 was

used because the supports in question were assumed to be mechanical

equipment as they were associated with the RHR pumps; thus, SSP-52 would

apply. At the time of the installation, SSP-52 did not include

sufficient detail to install the braces correctly.

III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

Subsequent to the NRC inspection, STP reinspected the bolted connections

on the RRR pump cross brace supports. Of the 124 bolted connections

inspected 33 had torque values lower than the specified range.

The

deficient bolts were documented on a Nonconformance Report (NCR) and

corrected per the NCR disposition.

The deficient bolts were retightened,

as necessary, utilizing the requirements of SSP-ll.

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STP has examined the potential for use of the incorrect procedure on

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other mechanical equipment supports.

Three areas were identified where

SSP 52 could have been used in error to install structural supports for

mechanical equipment:

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Attachment

ST-HL-AE-2308

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File No.: G2.4

Page 4 of 4

a.

RHR pump supports,

b.

RHR Heat exchanger lateral supports, and

c.

pressurizer lateral supports.

Of these supports, only the RHR pump supports previously identified were

of concern,

The RRR heat exchanger lateral supports have no bolted

steel-to-steel structural connections, and the pressurizer lateral

supports utilize bolting materials for which Westinghouse has specified

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turn-of-the-nut method tightening requirements.

IV. CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE

Prior to the NRC inspection, but after installation of the 7MR pump

supports, STP recognized the limited provisions in SSP-52 for

installation of structural bolted connections. Accordingly, SSP-52 was

revised to require the use of SSP-ll for general structural support

erection associated with mechanical equipment installation.

Proj ect

personnel have received training on this revision through the normal

training program concerning revisions to SSPs.

IV. DATE OF FULL COMPLIANCE

STP is in full compliance with regard to this violation at this time.

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