IR 05000498/1988038

Ack Receipt of 880819 & 1003 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/88-38 & 50-499/88-38

ML20205M350
Person / Time
Site:	South Texas
Issue date:	10/21/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8811030049
Download: ML20205M350 (2)

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,- - OCT 21 Isa In Reply Refer To:

Dockets: 50-498/88-38 '

50-499/88-38 Houston Lighting & Power Company -

ATTN: J. H. Goldberg, Group Vice t President Nuclear 1 P.O. Box 1700 Houston, Texas 77001 7 Gentlemen:

Thank you for your letters, dated August 19 and October 3,1988, in

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response to our letterse dated July 20 and September 12, 1988. We have no further questions at this time and will review your corrective action during a future inspectio Sincerel .

Orhinal Signed By A. D. Beach i

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L. J. Callan, Director Division of Reactor Projects ,

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CC: i Houston Lighting & Power Company '

ATTN: M. A. McBurnett, Manager Operations Support Li ensing P.O. Box 289  ;

Wadsworth, Texas 77483  ;

Houston Lighting & Power Corpany (

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ATTN: Gerald E. Vaughn, Vice President Nucl(ar Operations l P.O. Box 289 L

Wadsworth, Texas 77483

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Fouston Lighting & Power Corpany

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ATTN: J. T. Westenneter, General MarIager South Texas Project f/ f

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P.O. Box 289 /)T Wadsworth Texas 77483 / ,

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FDG ADOCK 05000498 O PDC o]

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Houston Lighting & Power Compan ,

Central Power & Light Company

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R. L. Range /R. P. Verret

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l Corpus Christi, Texas 78403 City of Austin Electric Utility ATTN: R. J. Miner, Chief Operating Officer l 721 Barton Springs Road  :

Austin, Texas 78704 .!

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Newman & Holtzinger, ATTN: J. R. Newman, Esquire l 1615 L Strcet, :

Washington, D.C. 20036  ;

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Houston Lighting & Power Company i

ATTN: S. L. Rosen P.O. Box 289 L

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Wadsworth, Texas 77483 Houston Lighting & Power Coepany ATTN: R. W. Chewning, Chairman Nuclear Safety Review Board -

P.O. Box 289 i Wadsworth Texas 77483  ;

i City Public Service Board ATTN: R. J. Costello/M. T. Hardt i P.O. Fox 1771 i San Antonio, Texas 78296 l Houston Lighting & Power Company  !

ATTN: Licensing Pepresentative l Suite 610  ;

Three Metro Center Bethesda, Maryland 20814 l Texas Radiation Control Program Director

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bec distrib. by RIV:

RRI-OPS i CRP

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SectionChief(DRP/0) DRS

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MIS System RPB-DRSS Lisa Shea, RM/ALF RIV File l R. Bachmann. OGC RSTS Operator j G. Dick, NRR Project Manager Project Engineer, ORP/0 RRI-CONST  !. Barnes L. Gilbert i

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August 19. 1988 ST-HL-AE- 2755 File No.: 0 CFR2.201 U. S. Nuclear Regulatory Comisaion Attention: Document Control Desk Washington. DC 20555

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South Texas Project Electric Generating Station Units 1 and 2 Docket Nos. STN 50-498. STN 50-499

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Response to Notice of Violation 498/499 88-38-01 Houston Lighting & Power Company has reviewed Notice of Violation 498/499 88-38-01 dated July 8. 1988, and submits the attached response pursuant to 10CFR2.20 If you should have any questions on this matter, please contact M M. T. Pelishak at (512) 972-707 '

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< f J. H. Goldberg Group Vice President. Nuclear MFP/hg Attachment: Response to Notice of Violation 498/499 8838 01

, n f% A subsidiary of Houston Industries incorporated fg& ,] O o ~ ~ g + 3 -p =:;. ( pl l L4/NRC/bs

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Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Cr ensel 611 Ryan Plaza Drive, suite 1000 Houston Lighting & vower Company Arlington, TX 76011 F. O. Box 1700 Houston, TX 77001 Coorge Dick, Project Manager U.S. Nuclear Regulatory Commission INPO Vashington, DC 20555 Records Center 1100 circle 75 Parkway Jack E. Bess Atlanta, CA 30339 3064 Resident Inspector / Operations e/o U.S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P. O. Box 910 Be11 port, NY 11713 Bay City, TX 77414

Don L. Carrison Resident Inspector / Construction c/o U.S. Nuclear Regulatory *

Commission P. O. Box 910 Bay City, TX 77414

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J. R. Newman, Esquire Newman & Holtzinger, t Street, Vashin,*3n DC 20036 R. L. Range /R. F. Verret Central Fover & Light company F. O. Box 2121 Corpus Christi, TX 78403

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R. John Miner (2 copies)

Chief Operating Officer City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J. Costello/M T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296

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Revised 06/15/88 L4/NRC/bs i

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Attachment

, fenaton W & fceer Compan/

' ST-ML-AE-2755

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, File No.: C * Page 1 of 4 Response to Notice of violation 498/499 88-38 01 I. Statement of Violation -

During an NRC inspection conducted on June 27 througT July 1. 1988 the following violation of NRC requirements was identified for failure to .

follow instructions for measuring remaining pipe wall thicknes Criterion V of Appendix 1 to 10 CFR Part 50 requires that activities l affecting quality shall be prescribed by documented instructions of a I type appropriate to the circumstances and shall be accomplis ~ned in  ;

accordance with these instructions. This requirement is amplified by the

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approved Quality Assurance Program Description (QAPD) of the South Texas Projec [

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A nonconformance report. NCR SS 05553, required the removal of a magnetic ,

particle examination indication from pipe spool A7 2012-H. The . L instructions of the nonconformar.ce report were to excavate the indication but not go below a remaining wall thickness of 0.417 inc '

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Contrary to the above NCR SS-05553 was improperly closed in that ultrasonic thickness measurements, made after quality control (QC) [

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closeout of the NCR. showed that the actual remaining wall thickness in f ti.c axcavation area was 0.%18 inch. Initial QC acceptance was determined

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l subseque.tiv to have been the result of use of an incorrect inspection l method (i.e. estimating remaining wall thickness by subtracting depth of l excavation from pipe nominal wall thidness).

II. Reason for Violation . t The implementing procedures utilized for Quality Control verificat;on of i existing pipe wall thickness were misinterpreted by Quality Control  !

inspection personnel, and the pipe wall thickness was determined by ,

subtracting the depth of excavation from the nominal pipe wall thicknes III. Corrective Action Taken and Results Achieve _d j i

As comunitted by H1AP in the July 1.1988 NAC Exit interview, a review of

- Customer Notification Forms (ChTs), initiated by Southwest Research Institute, the project Preservice Inspection (PSI) contractor, has been ,

completed to identify if any additional minimum pipe wall violations have r resulted due to QC inspectors using nominal wall thickness tables and [

depth cf excavation for determining remaining wall thicknes ;

ChT(s) which identified surface and heat affected zone indications were (

reviewed. Counterbored piping prepared for Pre-Service and In-Service l

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weld inspection and receiving subsequent surface metal reduction represented the areas of concern or worst case scenarios. Two hundred and four (204) Unit 1 and Unit 2 C!T s were identified as applicable.

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,N A N" C "T*"/ ST-HL AE-2755 '

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File No.: G . Page 2 of 4 l A thorough review of CNT'a and associated documentation was performed to identify instances where grinding took place. Those records thus identified as involving measurement of pipe wall thickness were then reviewed to determine the method utilize The Unit 1 CNF review did not identify any wall thickness violations due to indication removal. Additionally, no condition was identified where remaining wall thickness had been determined by subtracting the depth of excavation from pipe nominal wall thicknes The Unit 2 review revealed one (1) similar condition whereby remaining wall thickness was determined by subtracting the depth of excavation from pipe nominal wall thickness. Subsequent Ultrasonic Testin; (UT) verified this pipe wall thickness to be acceptable.

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The review of Unit 1 and Unit 2 Pre Service Inspection CNFs has been completed. No case, other than NCR SS 05553. vas identified where minimum wall violations have occurred due to Pre-Service Inspection Non-Destructive Examination indication remova IV. Corrective Steps Taken to Prevent Recurrence

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STP plant maintenance procedures provide adequate inspection guidelines to prevent misinterpretation of pipe wall measurement method. They do not permit the estimating of remaining wall thickness by subtracting the depth of excavation from the pipe's nominal wall thickness valu Ultrasonic Testing or measurecent of remaining pipe wall thickness using calibrated equipment is require Construction Site Standard Procedure (SSP-18) "General ASME III Welding Requirements" and Sita Standard Procedure (SSP-17). "General ANSI B3 Welding Requirements", which provide inspection guidelines for determining pipe wall thickness utilizing mechanical means have been revised. A standard measuring device such as a caliper or micrometer is required to measure actual remaining wall thickness where accessibl Where inaccessible for utilizing a standard cassuring device, direct ultrasonic testing may be used. When direct ultrasonic testing of an

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area is not possible. UT is to be performed along the periphery of excavated areas and the thickness of the thinnest section determine The depth of excavaticn is measured utilizing an inspection instrument capable of reaching the bottom of the excavated area. This value is subtracted from the lowest UT reading achieved to determine remainica pipe .:all thicknes L4/NRC/bs

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Attochment Houston lyhting, &.Buer CmTFF

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ST-HL-AEo2755

, File No.: G . Page 3 of 4 QC inspectors associated with piping installations have been instructed in use of the revised SSP-18 procedur Field engineering personnel associated with piping installation nave been instructed in use of the revised SSP-17 procedur V. , Additional Investinative Steps Taken and Resulte Achieved

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In addition to the aforementioned review of CNF's the projet t performed a review of Unit 2 programmatic do:uments utiliz(d at STP to riport discrepant piping surface conditions, to gain additional confidence that the NCR SS-05553 infringement of design minimum wall is an inslated occurrence. These documents are identified as follows, a

, 1) Base Material Surface Condition Reports (BMSCR)

2) Deficiency Noticos (DN)

3) Nonconformance Reports (NCR) .

Unit 2 documentation was treated as repressntative of conditions for the entire projec .

The review of these documents concentrated on repairs performed by grinding which did not require subsequent velding activities on Quality Clap. 1. 2 and 3 piping lines to identify if wall thickness was determined by subtracting the depth of excavation from the nominal wall thickness. This review was completed and revealed five additional cases of acceptance of items by Quality Control based on the depth of excavation subtracted from nominal vall thickness measurement metho Four (4) areas were identified on Deficiency Notices, and the other on a Fase Material Surface Condition Report. All five cases have been ultrasonically examined and found to be well above design minimum wall thickness. The renainias documents reviewed were found to be acceptable based on the mer.suremen' method performed (i.e., direct ultrasonic testing, or calibrated estrometer measurement) surface blend, or the affected area was repaired by veldin The project next reviewed ASKE piping systems for minimum pipe v;11 requirements. Portions of piping systems were identified where the excess wall between manufacturers minimum wall and calculated design mintrum wall is 1/32" or less. These lines (the most limiting cases)

were reviewed against the population of BKSCR's. DN's and NCR's previously discussed. No cases were found where the depth of excavation was subtracted from nominal vall thickness to obtain remaining pipe wal Unit 2 Quality Class 1 and 2 (vendor and field counterbored piping) and Quality Class 3 (field counterbored) piping lines were reviewed to determine locations where counterboring had been performed. This review included determining if repairs by grinding had been performed in the counterbored area to identify if remaining wall thicxness was determined by subtracting the depth of excavation from the nominal wall thicknes So/NRC/bs _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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s Attachment

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.M & M Cenpany ST ML AE 2755

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File No.: G <

Page 4 of 4 I i

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This review consisted of over 3,500 vaulted weld data packages and 2,900

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i pipe spool data Jackages. Thirteen (13) areas were identified where basemetal surfata condition repairs within the heat affected none (MAZ)

on the Pipe Pressure Soundary were accepted by Quality Control and the  !

mechanical measurement method used (i.e, caliper, micrometer or depth of excavation) was not clearly documented. After further evaluation six (6)

areas required wall thickness verification. Ultrasonic testing has been l performed on two of these areas and the wall thickness verified l acceptable. The remaining four (4) areas are inaccessible at this time l and are scheduled to be verified by September 30, 1988. This response will be supplemented by October 14, 1988 with the results of the remaining wall thickness measurement The investigation to date of Unit 2 Class 1, 2 and 3 counterbored welds, I the review of Bechtel identified piping lines having the least excess t wall thickness, and the review of BMSCR's DN's, and NCR's for ASME  !'

! piping, yields a high confidence level for the Project (Unit 1 and 2)

. that infringement of design minimum wall per NCR $$-05553 thus far is an

) isolated occurrence and no additional reviews are necessary beyond the  ;

j remaining four verifications discussed in the previous paragrap i

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VI. Date of Full Complianca ,

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l HL&P is in full complianc '

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company Housson Ughting at Power PO. Box 1700 Houston. Texas 77001 (715) 228 9211 Octobe r 3,1988 ,

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ST HL.AE 2C02 Pile No.:C ,

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Vashington, DC 20555 South Texas Project Electric Cenerating Station Units 1 and 2 Docket Nos. STN 50 498, STN 50 499 Supplemental Response to Nottee of Violation 88 38 01 Reference (1) U$d*RC Letter to H1AP L. J. Callan to J. H. Coldberg, ST AE HL 91695 dated July 20, 198 (2) H14P Letter to USNRC, ST HL AE 2755; Response to Notice of Violation 498/499 88 38 0 (3) UShv. Letter to H1AP L. J. Callan to J. H. Goldberg, ST AE HL 91778 dated September 12, 198 Houston Lighting and Power Company responded to Notice of Violation 498/499 88 38 01 on August 19, 1988 (reference 2). Our rispense indicated that, at that time, four (4) areas which required wall thickness verification were inaccessible. These four areas have subsequently been ultrasonically examined and found to be acceptabl If you should have any questions on this matter, please contact M M. F. Polishak at (512) 972 707 ,

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J. H. Coldberg Group Vice President, Nucleat MTP/SDP/hg

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A Subsidiary of Houston Industries Incorporated

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File No.: C .

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cm Regional Administrator, Region IV Nuclear Regulatory Commission Rufus S. Scott 611 Ryan Plaza Drive, suite 1000 Associate General Counsel Arlington, TX 76011 Houston Lighting & Power Company P. O. Box 1700 George Dick, Project Manager Houston, TX 77001 U.S. Nuclear Regulatory Commission INPO Vashington, DC 20555 Records Center Jack E. Sess 1100 circle 75 Parkvay Senior Resident Inspector / Operations Atlanta, CA 30339 3064 e/o U.S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission P. O. Box 910 50 Se11 port lane Bay City. TX 77414 Bellport, NY 11713 J. 1. Tapia Senior Resident Inspector / Construction c/o U.S. Nuclear Regulatory Cormission P. O. Box 910 Bay City. TX 77414

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J. R. Nevaan. Esquire Nevean & Holtzinger, L Street, Vashington, DC 20036 R. L. Range /R. P. Verret Central Power & Light Company P. O. Box 2121 Corpus Christi. TX 78403 R. John Minor (2 copies)

Chief Operatiel Officer City of Austin Electric Utility 721 Barton Springs Road Austin. TX 78704 R. J. Costello/M. T. Hardt City Public Service Roard P. O. Box 1771 San Antonio. TX 78296 Revised 08/24/88 LA\NRC\ck