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The Lightc o m p a n y South Texas Project Electric Generating StationP. O. Box 289 Wadsworth, Texas 77483Ho Li@ig & Pom

January 3, 1994ST-HL-AE-4659File No.: G02.04.0210CFR2.201

U. S. Nuclear Regulatory CommissionAttention: Document Control Deskwashington, DC 20555

South Texas ProjectUnit 2

Docket No. 50-499Reply to Notice of Violation 93036-2

Recardino A Freeze Seal That Was Not Established

Houston Lighting & Power has reviewed Notice of Violation 93036-2,dated December 2, 1993 regarding a freeze seal that was notestablished in accordance with procedural guidance and submits ourreply in Attachment 1. The inability to form a freeze seal did nothave an adverse effect on safety related systems, but clearly doesnot reflect the standards of performance expected at South TexasProject.

As a result of the investigation of this and other recentoccurrences, Houston Lighting & Power has identified contractorcontrol and performance monitoring as an area requiring increasedemphasis. This increased emphasis is addressed in Attachment 2.

If there are any questions please contact Mr. S. M. -Head at(512) 972-7136 or me at (512) 972-8664.

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LkW L /fT F. roth

070003 vice president,Nuclear Generation

DNB/eg

Attachment: 1. Reply to Notice of Violation 93036-2

2. Contractor Control and Oversight

'Project Manager on Behalf of the Participants in the South Texas Project |

I1R-93\p3 354.001 9401110156 940103@k bsPDR ADOCK 05000499

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Houston Lighting & Power Company ST-HL-AE-4659=Soutli Texas Project Electric Generating Station File No.: G02.04.02

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Regional Administrator, Region IV Rufus S. ScottU. S. Nuclear Regulatory Commission Associate General Counsel611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power CompanyArlington, TX 76011 P. O. Box 61867

Houston, TX- 77208

Lawrence E. Kokajko Institute of Nuclear PowerProject Manager Operations - Records CenterU. S. Nuclear Regulatory Commission 700 Galleria. ParkwayWashington, DC 20555 13H15 Atlanta, GA 30339-5957

David P. Loveless Dr. Joseph M. HendrieSr. Resident Inspector 50-Bellport Lanec/o U.S. Nuclear Regulatory Comm. Bellport, NY 11713P. O. Box 910Bay City, TX 77404-910

J.'R. Newman, Esquire D. K.-LackerNewman & Holtzinger, P.C., STE 1000 Bureau of Radiation Control1615 L Street, N.W. Texas Department of HealthWashington, DC 20036 1100 West 49th Street

Austin, TX 78756-3189

G. E. Vaughn/T. M. PuckettCentral Power and Light CompanyP. O. Box 2121Corpus Christi, TX 78403

J. C. Lanier/M. B. LeeCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704

K. J. Fiedler/M. T. HardtCity Public ServiceP. O. Box 1771San Antonio, TX 78296

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IR-93\93-354.001

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' Attachment 1'

ST-HL-AE-4659.-Page 1 of 3

i I. Statement of Violation:!

Technical Specification 6.8.1.a states, in part, thatwritten procedures shall be established, implemented, and ,

maintained including the applicable procedures' recommended.~

in Appendix A of Regulatory. Guide 1.33, Revision 2,February 1978. Item 9.a of Appendix A states, in'part, ,

" Maintenance that can affect the performance of safety-related equipment should be properly preplanned andperformed in accordance with written procedures,documented instructions, or drawings appropriate to the

| circumstances."l! This requirement was implemented, in part,fby Procedure| MNP-1004, " Freeze Stop. Procedure," Revision 1.I Step 4.10.9 states, "Upon reaching the freeze stop

temperature outside the jacket at the thermo-couple record-

| the time, inspect the jacket, notify the customer; freeze ,

| stop plug and release pipe for work to be done.by.customer."

| Contrary to the above, at or,about 5:05 a.m. onOctober 13, 1993, the contractor technician notifiedlicensee personnel that a freeze plug hadLbeenestablished, and Progress Record Sequence 85 of WorkPackage 308833-EP01 was signed'off, thereby releasing the- i

pipe for work, without achieving-the freeze.stoptemperature outside the jacket. Testing later verified-that the freeze plug had not been-established.

This is a Severity Level IV violation. '(Supplement I)(499/93036-2)

II. Houston Lichtina & Power Position:

Houston Lighting & Power concurs that the violation- '

occurred.

III. Reason for Violation:

| The procedure violation was caused by a cognitive error onthe part of a freeze seal technician who was supplied by.a,

| freeze seal specialist company. 'Two freeze seals were| being formed to isolate a section of piping to be| breached. When the two freeze seals-were being formed,

the temperature for one end of the jacket on one freeze'

seal had not decreased to a temperature that wouldindicate the freeze seal had formed. A valve between thetwo freeze seals was opened to check the' formation of the

| freeze seals and no water came out. A pump.was' started to-| further test the integrity of the freeze seals. Uponj starting the pump, the-freeze seals failed.

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Attachment 1ST-HL-AE-4659Page 2 of 3

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Extensive pre-planning was performed to ensure that thefreeze seal effort would be successful. Points of contactfor Houston Lighting & Power were designated to ensureproper coordination and control of the work.Qualification interviews were conducted with the personnel

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supplied by the freeze seal specialist company todetermine that they possessed adequate experience andknowledge to establish and maintain ~the freeze seals.Only those personnel who demonstrated adequate knowledgeand experience were allowed to perform the work. A systemwalkdown was performed with the contractor personnel to

| ensure that freeze seals were feasible in the desiredi locations and system configuration. A pre-job briefing

was performed with the contractor personnel prior to-work'start. Contractor personnel were subject to HoustonLighting & Power overtime restrictions to prevent fatigue

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| related errors.,

The freeze seal technician who prematurely released thefreeze seals for testing had previous experience ]

establishing and maintaining freeze seals at other nuclearfacilities. The technician also demonstrated satisfactory ,

knowledge during the interview administered by the !utility. Despite adequate knowledge and experience, the |technician did not establish the freeze seals correctly.

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| IV. Corrective Actions:'

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The Houston Lighting & Power organizations responsible for i

the work in progress and the contractor-freeze. seal |company met and determined that a: successful freeze" seal !

!was not probable under the existing conditions. Thefreeze seal effort was cancelled and-the required. work was:rescheduled for a work window in which freeze' seals wouldnot be required.

For this type of work, the' contractor possessed specific-expertise and this expertise was the basis for_ determiningwhen the freeze seal had~been formed. The contractor's.procedure did not specify temperature criteria'forformation of the freeze seal-because the procedure.is used-for a variety of fluids which freeze.at differenttemperatures. Houston Lighting & Power had called thecontractor prior to the work being performed and obtained'a temperature of. -20 F, which was_used.in-the Houston-Lighting & Power 50.59_ evaluation.~ Because the contractorihad provided this value,: Houston Lighting &' Power assumedthe contractor would be usingL -20 F in-performing' thefreeze seals. However, this temperature.was notLspecified-in the work instructions for determining that the freezeseals were properly formed.

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|Attachment 1ST-HL-AE-4659 *

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To preclude recurrence, a requirement will be added toboth the Houston Lighting & Power and' contractor freezeseal procedures to ensure that temperature criteria arespecified for determining that freeze seals.have been :

I formed. The Houston Lighting & Power procedures andcontractor procedures will be revised by January 5, 1994~r

{ and January 31, respectively, to require specification of| temperature criteria. Freeze seals will not be used priorj to the procedures being revised.

V. Date of Full Comoliance:.

Houston Lighting &' Power is in full compliance.

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Attachment 2ST-HL-AE-4659Page 1 of 3

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Contractor Control and Performance Monitorina,

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Discussion,

Subsequent to the freeze seal not being properly established, two.,

more examples of substandard work performance by contractors have i

occurred.

On November 22, 1993, contract workers were performing,

| maintenance on Unit 2 motor operated valvec. The work packages| were written for motor operated valves in the Containment Spray

System, but work was actually performed on motor operated' valves-in the Safety Injection System. A Reactor Plant Operatorperforming rounds identified that the wrong valves were beingworked. The error did not cause plant system damage,degradation, or loss of function and did not result in personnel-injury or spread of radioactive contamination. The root causewas determined to be inattention to detail. Corrective actionsto address this occurrence included issuing a stop work order formotor operated valve activities, disciplining workers involved in

: the occurrence, defining work expectations, adding seniormaintenance personnel to provide performance monitoring andi

ensure that work expectations are being met, and. requiring thecontractor to increase field supervision and communicate workexpectations to the workers.

On December 6, 1993, contract workers removed two Unit 2temperature switches for calibration. The temperature switcheswere calibrated and upon reinstallation were inadvertentlyswapped. The Quality Control inspector identified that theswitches were installed in the wrong locations. The root causewas determined to be inadequate work practices.in that self-checking was not used. Corrective actions to address thisoccurrence included issuing a.stop work order'for~ Unit-2,- .

revoking the access of the workers involved in the occurrence, j

issuing a plant bulletin on self checking, conducting shopmeetings to discuss attention to detail, self-checking,.andaccountability, and craft supervisors-performing a positive icontact session with workers on self-checking.

In addition, Quality Assurance performed an audit.of Training and-L Qualification in November, 1993. Quality Assurance identified a'

continuing problem with the verification of specialty contractorpersonnel qualifications.

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Attachment 2-ST HL-AE-4659Page 2 of 3

Generic Imolications

Houston Lighting & Power was concerned that contract workers hadbeen involved in three recent occurrences which may have had moreserious consequences. Because of this concern and the issueidentified by Quality Assurance, a task group was formed toreview the adequacy of the current program for contractor controland performance monitoring.

The current program was the result of actions to correct adeficiency with contractor control and performance monitoringidentified in 1992. These actions included enhancing theprocedure for procurement of services and issuing a procedure.that provided guidance on contract management,1 monitoring,reporting and rating. The procedure delineated responsibilitiesfor the Contract Technical Coordinator that-included monitoringthe contractor's work and quality of work. Personnel filling-

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positions of responsibility defined by the procedure _werei trained.

The task group has reviewed the. current program and concluded-that the program is adequate, but that.managementEneeded toclearly communicate their expectations to the' Contract TechnicalL

| Coordinators with regards to the Contract Technical Coordinator'sduties and responsibilities. Based on the task group's

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conclusion, a policy statement on contractor control andperformance monitoring has been written-that clearly communicatesManagement's expectations. The policy clearly establishes'thatthe Contract Technical Coordinator is responsible for ensuringthat Houston Lighting & Power expectationsLare explicitly statedin procurement' documents, reviewing the contractor's management-plan and supervisory. organization to ensure that the contractor i

has an appropriate management structureLand field supervisoryi

practices, and preparing an accompanying Houston Lighting & Power |

| management performance monitoring plan to ensure that contractorperformance satisfies Houston Lighting & Power's statedexpectations. The policy clearly states that the-ContractTechnical Coordinator is responsible for the performance of thecontracted work. !

Training on management's expectations, as contained in the ;

policy, was provided to.the groups involved in the'abovedescribed occurrences. The remaining. contract Technical :,

L Coordinator's will receive initial training on management's| expectations by January 18, 1994.i!

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Attachment 2-

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ST-HL-NS-4659Page 3 of 3 :

In addition, Houston Lighting & Power is reevaluating theassignment of the Contractor Technical Coordinators to' ensurethat the most appropriate organization is overseeing the work.This reevaluation is a result of the recent maintenance performed i

on the wrong motor operated valves. Following that occurrence,Houston Lighting & Power changed the oversight organization forthe motor operated valve work from Engineering to Maintenancebecause Maintenance was better suited to oversee the type of workcurrently being performed by the motor operated valve contractor.Reevaluation of Contract Technical Coordinator assignments foropen field contracts will be completed by January 31, 1994.

In summary, actions taken and proposed to address contractorcontrol and performance monitoring require reviewing contractormanagement plans and supervisory organizations including. fieldsupervision, preparing and using accompanying Houston Lighting &Power management performance monitoring plans, assigning Contract

I Technical Coordinators from appropriate organizations to overseecontractor work, and communicating these requirements andexpectations to the appropriate personnel. These~ actions shouldpreclude recurrence of substandard work performance. i

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