IR 05000498/1993014
| ML20059D607 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/04/1994 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9401100015 | |
| Download: ML20059D607 (5) | |
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o UNITED STATES
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k NUCLEAR REGULATORY COMMISSION
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o R EGION IV k
"E 611 RYAN PLAZA DRIVE, SUITE 400 g-
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ARLtNGTON, TEXAS 76011-8064
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l JAN - 41994
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Dockets:
50-498 50-499 Licenses:
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Houston Lighting & Power Company
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ATTN: William T. Cottle, Group
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Vice President, Nuclear P.O. Box 289
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Wadsworth, Texas 77483 SUBJECT:
NRC INSPECTION REPORT 50-498/93-14; 50-499/93-14 f
Thank you for your letters of May 13 and 21~,1993, in response to our letter and Notice of Violation dated April 13, 1993. We have reviewed your reply and find it responsive to the concerns raised in Violation'498; 499/9314-01 and i
Example 1 of Violation 498/9314-02. We will review the implementation of your
corrective actions during a future inspection'to_ determine that full
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compliance has been achieved and will be maintained.
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With respect to your denial of Example 2 of Violation 498/9314-02, we-l acknowledge that the engineering analysis that was provided on Marr.h 26, 1993,
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subsequent to the inspection, demonstrated that the primary manway studs in Steam Generators lA and IB had not been tensioned beyond the minimum yield stress and were, therefore, acceptable for continued use.
Your letters of
May 13 and 21, 1993, indicate that the stud elongation data were reviewed by
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Engineering during Refueling Outage IRE 02 in 1990 and found acceptable. The stud elongation data and the engineering conclusion were stated to be
documented in Service Request (SR) 128151.
Our review of SR-128151 during the inspection did not find any engineering conclusion specifically documented in the work package. We held a conference call with Mr. M. Kanavos of your staff on June 16, 1993, to seek clarification of your response.regarding the documentation of the engineering review and conclusion.. No information was provided at that time, which would either indicate that the engineering review actions in 1990 were documented, or clarify why SR-128151 was considered to document the engineering conclusion.
In our view, it was not.until March 1993, when the NRC questioned the adequacy of your actions, that. extensive analysis was performed to confirm the acceptability of the studs.
Accordingly, we continue to believe that the 1990 stud elongation _ measurements should have been treated as a condition adverse to quality and formally evaluated and documented for determination of required corrective actions.
Therefore, we believe the violation of 10 CFR Part 50, Appendix B, Criterion XVI, occurred as stated and will not be withdrawn.
In that the acceptability of the studs has'been established and reviews of your corrective
9401100015 940104
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PDR ADOCK 05000498 j
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t Houston Lighting & Pow 6r Company-2-
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action processes currently are being performed, we do not require an additional response on this subject.
If you have any questions concerning this matter, please contact Mr. Ian Barnes of my staff at 817-860-8176.
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irector Division of Reactor Safety cc:
Houston Lighting & Power Company ATTN:
James J. Sheppard, General Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483 City of Austin Electric Utility Department ATTN:
J. C. Lanier/M. B. Lee 721 Barton Springs Road Austin, Texas 78704
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City Public Service Board ATTN:
K. J. Fiedler/M. T. Hardt
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P.O. Box 1771 San Antonio, Texas 78296 Newman & Holtzinger, P. C.
ATTN: Jack R. Newman, Esq.
1615 L Street, NW Washington, D.C.
20036 Central Power and Light Company ATTN:
G. E. Vaughn/T. M. Puckett P.O. Box 2121 Corpus Christi, Texas 78403 INPO Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957
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Mr. Joseph M. Hendrie 50 Bellport Lane Bellport, New York 11713
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Houston Lighting & Power Company-3-i
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Bureau of Radiation Control
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State of Texas
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l 1100 West 49th Street
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Judge, Matagorda County
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Matagorda County Courthouse
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1700 Seventh Street Bay City, Texas 77414
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Licensing Representative
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Houston Lighting & Power Company Suite 610 Three Metro Center Bethesda, Maryland 20814 Houston Lighting & Power Company
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ATTN:
Rufus S. Scott, Associate l
General Counsel
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P.O. Box 61867 Houston, Texas 77208 i
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l JAN -- 41994 Houston Lighting & Power Company-4-
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J. L. Milhoan Resident Inspector Section Chief (DRP/A)
Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS
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RIV File
. Project Engineer-(DRP/A)
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R. Bachmann, OGC, MS: 15-B-18 Section Chief (DRP/TSS)
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bec to DMB-(IE01)
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J. L. Milhoan Resident Inspector i
Section Chief (DRP/A)
Lisa Shea, RM/ALF, MS: MNBB 4503 i
MIS System DRSS-FIPS l
RIV File Project Engineer (DRP/A)
R. Bachmann, OGC, MS: 15-B-18 Section Chief (DRP/TSS)
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May 13, 1993
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ST-HL-AE-4420
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File No. G02.04 10CFR2.201 U.
S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 l
South Texas Project Units 1 and 2
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Docket Nos. STN 50-498; STN 50-499 l
Reply to Notice of Violation 9314-01
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Reaardina Failure to Complete Boric Acid Leakaae Docurnentation l
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Houston Lighting & Power Company (HL&P) has reviewed Notice of
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Violation 9314-01 dated April 13, 1993, and submits the attached j
reply.
If there are any questions regarding this matter, please contact Mr.
A.
W.
Harrison at-(512)
972-7298 or me at (512) 972-7921.
\\f W. H. Ki ehr.
Vice President, i
Nuclear Generation
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Attachment: Reply to Notice of Violation 9314-01
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l IRt93-119.001
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Project Manager on Behalf of the Participanu in the South Texas Project f
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ST-HL-AE-4420 Houston Lighting & Power Company File No.: G02.04
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South Texas Project Electric Generating Station Page 2 c:
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Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 Lawrence E. Kokajko Project Manager U.S. Nuclear Regulatory Commission Institute of Nuclear Power Washington, DC 20555 13H15 Operations - Records Center 700 Galleria Parkway J.
I. Tapia Atlanta, GA 30339-5957 Senior Resident Inspector c/o U.
S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P.
O.
Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker J.
R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C.,
STE 1000 Texas Departmer.t of Health 1615 L Street, N.W.
1100 West 49th Street Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M.
Puckett U.S. Nuclear Regulatory Comm.
Central Power and Light Company Attn:
Document Control Desk P.
O.
Box 2121 Washington, D.C.
20555 Corpus Christi, TX 78403 J.
C. Lanier/M.
B.
Lee City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 K. J. Fiedler/M. T. Hardt City Public Service P.
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Box 1771 San Antonio, TX 78296 l
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Attachment ST-HL-AE-4420 Page 1 of 2 i
Reply to Notice of Violation 9314-01 I. Statement of Violation:
i Criterion V of 10 CFR 50, Appendix B,
states, in part,
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in i
accordance with these instructions, procedures, or
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drawings.
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Paragraph 4.1.2 of Station Procedure OPG-P03-ZE-0033, "RCS Pressure Boundary Inspection for Boric Acid Leaks," Revision 0 (effective date August 1,1998) through Revision 4 (effective date February 23, 1993) states, in part, " Form (-2) will be
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completed for each leak or evidence of leak found.
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Contrary to the above:
1.
Form (-2)s were not. completed for five instances of evidence of leakage tht.t were found during a Unit 2 reactor coolant system walkdown inspection performed on July 14,1989. Inspection areas where evidence of leakage was observed included reactor vessel head instrumentation penetrations and pressurizer instrument ports,. root valves, and lines.
2.
Form (-2)s were not completed for two instances of evidence of leakage at steam generator primary manway covers, that were found during a Unit 1 reactor coolant system walkdown inspection performed on March 14, 1992.
These two examples constitute one Severity Level IV violation (Supplement I) (498;499/9314-01).
II. Houston Lichtina & Power Position:
HL&P concurs that the cited violation occurred.
III. Reason for Violation:
The system engineer performing the walkdown did not perform the administrative requirements in a timely manner.
The standard for timely completion of administrative requirements was not adequately communicated or enforced.
The system engineer felt that initiation of corrective action documents was sufficient to satisfy the intent of the procedure.
IR\\93-119.001
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Attachment ST-HL-AE-4420 Page 2 of 2 IV. Corrective Actions:
1.
Four of the five items identified in the July 14, 1989 walkdown, for whien Form (-2) had not been completed, have been verified as repaired. The fifth item did not have a Service Request issued, but subsequent walkdowns have not identified any leak or evidence of a leak on the component.
2.
The two items identified in the March 14, 1992 walkdown, for which Form (-2) had not been completed, were repaired during the forced outage which commenced in February 1993.
3.
Procedure OPGP03-ZE-0033 was revised effective February 2, 1993 to require completion and submittal of the inspection forms and associated service requests within twelve hours of walkdown completion.
4.
The individual who did not complete the Form (-2)s is no longer the system engineer.
The current system engineer participated in the investigation of this violation and in developing the corrective actions.
He was also involved in generating the procedure revision that requires submittal of the forms within twelve hours of walkdown completion.
He is very aware of the significance of performing the administrative requirements in a timely manner.
5.
All previously completed OPGP03-ZE-0033 walkdown documentation has been reviewed for accuracy and completeness.
Information missing from completed forms has been added as inspection supplements.
6.
The standards for documentation processing will be communicated to system engineers.
(Completion date: May 31, 1993)
7.
As an enhancement, a supervisor review block will be added to Form (-1)
to ensure completion in accordance with the procedure. (Completion date: May 31, 1993)
V.
Date of Full Compliance:
HL&P is in full compliance.
IR\\93-119.001
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The Light c o m p a ny South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, Texas 77483 Houston Lighting & Power
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\\D E l PQ May 13, 1993 ST-HL-AE-4444 File No.:
G02.04 10CFR2.201 U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50-498 Reply to Notice of Violation 9314-02 Regarding Failure to Perform Corrective Maintenance and Exceedinc Manway Cover Stud Eloncation Measurements Houston Lighting & Power Company (HL&P) has reviewed Notice of Violation 9314-02 dated April 13, 1993, and submits the attached reply.
HL&P will submit a supplemental report on this Notice of Violation to describe the corrective action to prevent recurrence of Example IA.
The supplemental report will be submitted by May 21, 1993.
If there are any questions regarding this matter, please contact Mr.
A.
W.
Harrison at (512)
972-7298 or me at (512) 972-7138.
+4 S.
Rosen
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Vice President, Nuclear Engineering HRP/nl Attachment:
Reply to Notice of Violation 9314-02
'T 3 - f 17 4, IR\\93-125.001 A Subsidiary of Houston Industries incorporated A
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ST-HL-AE-4444 Houston Lighting & Power Company File No.: G02.04
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South Texas Project Electric Generating Station Page 2
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Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel
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611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P. O.
Box 61867 Houston, TX 77208 Lawrence E. Kokaj ko Project Manager U.S. Nuclear Regulatory Commission-Institute of Nuclear Power Washington, DC 20555 13H15 Operations Records Center
700 Galleria Parkway f
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I. Tapia Atlanta, GA 30339-5957 Senior Resident Inspector c/o U.
S.
Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P.
O.
Box 910 Bellport, NY 11713
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Bay City, TX 77414 D. K.
Lacker J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C.,
STE 1000 Texas Department of Health 1615 L Street, N.W.
1100 West 49th Street Washington, DC 20036
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Austin, TX 78756-3189
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D. E. Ward /T. M.
Puckett U.S. Nuclear Regulatory Comm.
Central Power and Light Company Attn:
Document Control Desk P.
O.
Box 2121 Washington, D.C.
20555 Corpus Christi, TX 78403 J.
C. Lanier/M.
B.
Lee City of Austin Electric Utility Department 721 Barton Springs Road j
Austin, TX 78704 j
K. J. Fiedler/M. T. Hardt City Public Service
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P.
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Box 1771 San Antonio, TX 78296
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Attachment ST-HL-AE-4444 Page 1 of 5 Reply to Notice of Violation 9314-02 I.
Statement of Violation:
Criterion XVI of 10 CFR 50, Appendix B, states, in part,
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, I
deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected..."
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Contrary to the above:
A.
Corrective maintenance was not promptly performed in regard to the identification on March 28, 1991, of
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evidence of leakage at the Steam Generator 1B hot leg primary side manway cover (i.e., boric acid crystals were observed to be present at bolts 3, 5, and 14).
An outstanding service request, SG-115696, which was intended to correct this condition, remained unplanned as of the February 25, 1993, discovery date of active leakage at this manway.
B.
Elongation measurements in April 1990, of the hot leg and cold log primary side manway cover studs for Steam Generator 1A and 1B resulted in values which exceeded the permissibic range stipulated by Department Procedure OPMPO4-RC-0004, " Steam Generator Primary Manway Cover Removal and Reinstallation," Revision 6.
These values were neither ideatified as a nonconforming condition, nor formally evaluated for determination of required corrective actions.
These two examples constitute one Severity Level IV violation (Supplement I) (498/9314-02)
II.
Houston Lichtina & Power Position on Example IA of Cited Violation:
HL&P concurs with example IA of the cited violation.
III. Reason for Violation:
On May 03, 1991, Service Request (SR) SG-115643, which was initiated to repair boric acid leakage bolts 3, 5, and 14 on Steam Generator 1B, was voided.
The work activity for SG-115643 was to be performed on SG-115696.
The additional scope of work was noted on SR SG-115696.
SG-115696,
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originally scheduled for Unit 1 Fourth Refueling Outage I
(1RE04), was rescheduled.
Personnel rescheduling the work were unaware of the additional scope transferred from the voided SR SG-115643.
J IR\\93-125.001
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Attachment ST-HL-AE-3444 Page 2 of 5 Reply to Notice of Violation 9314-02
IV.
Corrective Actions:
The boric acid leaks were corrected under SRs SG-158293 and SG-179924.
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The Work Management System (WMS) entry for SG-115696, a
recurrent SR to perform plant maintenance-on the steam generator during outages, has been upde'
.1 to include the additional work scope of the voided SG.1.15643.
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V.
Date of Full Compliance:
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HL&P is in full compliance.
VI.
Houston Lichtina & Power Position in ExamDie IB of Cited Violation:
JL&P does not concur with example IB of the cited v'.olation.
HL&P does not consider _that the data constituted a nonconforming condition.
As such, no further remedial or ccrrective action was deemed necessary.
VII. Basis For Disputina Example IB of Cited Violation:
During Unit 1 First Refueling Outage (1RE01), the primary manway closure stud elongation was measured using digital depth micrometers.
Following the outage, the digital depth micrometers were decontaminated and returned to the Metrology
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Laboratory (MET Lab) for scheduled calibration.
The instruments were found corroded and calibration was impossible.
A Metroloav Laboratory Evaluation Form was generated to document the condition of the instruments, the lack of "as found" data, and the acticn required.
A Service Request (SR) 128151 was initiated to verify the as-left stud elongation measurements on SGs 1A, 1B, 1C, and 1D during the
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Unit 1 Second Refueling Outage (1RE02).
Since the originating problem was identified on the Met Lab Evaluation Form, a SR was selected to track and document this action.
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IR\\93-125.001
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ST-HL-AE-4444 Page 3 of 5 Reply to Notice of Violation 9314-02
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VII. Basis For Discutina ExamDie IB of Cited Violation: (Con't)
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During 1RE02, stud elongation measurements were taken on all primary manway closure studs as required by SR 128151.
Two sets of stud elongation measurements were requested by Plant Engineering Department (PED), one using a standard depth micrometer and the second using a digital depth micrometer.
The results were to be reported to PED for an engineering evaluation.
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The two sets of elongation measurements yielded data which was not comparable to the 1RE01 as-left stud elongation
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measurements since they showed an apparent growth.
However, the original (1RE01) stud elongation data was evaluated by
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Engineering and was deemed to be acceptable, and no further action was required based on:
1RE01 relaxed stud length (baseline) measurements were e
considered questionable since the instruments used did
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not receive a post calibration and the 1RE02 as-found
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measurements showed an apparent increase in stud lengths.
j Stud elongation is not possible without additional force s
e applied.
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1RE01 total elongation values (difference of the relaxed e
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stud length and tensioned length) were considered
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correct.
Variables that affect stud elongation (stud temperature e
i and primary system pressure and temperature) were not l
recorded nor controlled during 1RE01 or 1RE02.
Stud temperature affects the relative lengths of the stud and
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i the internal rod as a result of the different thermal
i expansions of these materials.
Primary system pressure j
affects the magnitude of the forces exe-+
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and changes the stud length.
Primary s stm temperature
y affects the stud temperature.
Thereft 2,
ysasurements taken at atmospheric pressure will vat f sm measurements
i taken with the primary system pressurised.
I In March, 1993, the NRC staff reviewed copies of elongation
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data compiled from 1RE01 through 1RE04.
From that review,.the j
NRC staff concluded that there was an apparent growth in stud length to the point of plastic deformation.
The NRC staff requested HL&P to justify the acceptability of the studs prior to the Unit 1 startup.
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IR\\93-125.001
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Attachment ST-HL-AE-4444
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Reply to Notice of Violation 9314-02 VII. Basis For Disputina Example IB of-Cited Violation: (Con't)
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HL&P provided justification for the acceptability of the studs ~
during a conference call on March 26, 1993.
This
justification included an evaluation of the original 1RE01
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i relaxed stud length data, a calculation of the elongation necessary to exceed minimum yield, an evaluation of the stud tensioning equipment capability to plastica 11y deform the studs, and the result of the standard go/no-go gauge tests.
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I This justification included the following points:
The original 1RE01 data was approximately 0.004 inches'
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shorter than data obtained in 1RE02.
Data taken in
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t February, 1993, indicates that there is good corroboration with the 1RE02 measurements.
The original baseline measurements taken in 1RE01 probably do not l
represent the actual dimension.
However, these values do
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provide the correct magnitude of the distance from the top of the stud to the internal rod.
An engineering calculation determined that a total
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e elongation of 0.0241 inches would be required to reach the minimum stud yield stress.
A comparison of the
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relaxed stud length data to the 1RE02 elongation measurements, shows that no studs were stressed beyond yield.
The equipment and procedures used to tension the studs e
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were evaluated for the capability to stretch the studs beyond the minimum yield stress.
Using conservative assumptions, the maximum stretch the equipment could produce was 0.0167 inches which is below the 0.0241 inches required for minimum yield.
Therefore, the equipment capacity and procedure guidelines preclude the studs from being stretched beyond yield.
The result of the standard go/no-go gauge tests were e
evaluated and all but three passed these tests satisfactorily.
All studs exhibited elastic behavior
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when detensioned.
When the manway closure was assembled, the studs were retensioned successfully.
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IR\\93-125.001 i
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The Light
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Houston Lighting & Power May 21, 1993 ST-HL-AE-4467 File No.: GO2.04 10CFR2.201 t
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U.
S. Nuclear Regulatory Commission
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Attention:
Document Control Desk
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Washington, DC 20555 t'
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South Texas Project
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Unit 1 Docket No. STN 50-498 Reply to Notice of Violaticn 3314-02 Regarding Failure to Perform Corrective Maintenance and Exceeding Manway Cover Stud Elongation Measurements Sunnlemental Report Reference:
ST-HL-AE-4444, Reply to Notice of Violation 9314-02, dated May 13, 1993 Houston Lighting & Power Company (HL&P) has reviewed Notice of l
Violation 9314-02 dated April 13, 1993, and submits the attached revised reply as a supplemental report.
The Reply to Notice of Violation 9314-02 referenced above has been revised to include corrective actions to minimize recurrence of Example IA.
If there are any questions regarding this matter, please contact
?~'.
A.
W.
Harrison at (512)
972-7298 or me at (512) 972-7921.
Niht W.
H.
Kins
, Jr.
Vice President, Nuclear Generation l
HRP/sr Attachment:
Revised Reply to Notice of Violation 9314-02 IR\\93-137.001 Project Manager on Behalf gf 'I e Participants in the South Texas Project 2l
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Houston Lighting & Power Company ST-HL-AE-4467
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South Texas Project Electric Generating Station File No.: G02.04 Page 2
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i Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel
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611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston,_TX 77208 Project Manager
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U.S. Nuclear Regulatory Commission Institute of Nuclear Power i
Washington, DC 20555 Operations - Records Center
1100 Circle 75 Parkway
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I. Tapia Atlanta, GA 30339-3064
Senior Resident Inspector
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c/o U.
S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane
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Box 910 Bellport, NY 11713 Bay City, TX 77414 i
D.
K. Lacker
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J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C.,
STE 1000 Texas Department of Health
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1615 L Street, N.W.
1100 West 49th Street
Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett U.S. Nuclear Regulatory Comm.
Central Power and Light Company-Attn:
Document Control Desk j
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Box 2121 Washington, D.C.
20555 l
Corpus Christi, TX 78403
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C. Lanier/M. B. Lee
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City of Austin
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Electric Utility Department
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721 Barton Springs Road Austin, TX 78704
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J. Fiedler/M. T. Hardt
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City Public Service P.
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Box 1771
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San Antonio, TX 78296
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Attachment ST-HL-AE-4467 Page 1 of 5 Revised Reply to Notice of Violation 9314-02 I.
Statement of Violation:
Criterion XVI of 10 CFR 50, Appendix B, states, in part,
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected..."
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Contrary to the above:
A.
Corrective maintenance was not promptly performed in regard to the identification on March 28, 1991, of evidence of leakage at the Steam Generator 1B hot leg primary side manway cover (i.e., boric acid crystals were observed to be present at bolts 3, 5, and 14).
An outstanding service request, SG-115696, which was intended to correct this condition, remained unplanned as of the February 25, 1993, discovery date of active leakage at this manway.
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B.
Elongation measurements in April 1990, of the hot leg and cold leg primary side manway cover studs for Steam Generator 1A and 1B resulted in values which exceeded the
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permissible range stipulated by Department Procedure OPMPO4-RC-0004, " Steam Generator Primary Manway Cover Removal and Reinstallation," Revision 6.
These values j
were neither identified as a nonconforming condition, nor formally evaluated for determination of required corrective actions.
These two examples constitute one Severity Level IV violation (Supplement I) (498/9314-02)
II.
Houston Lichtina & Power Position on Examole IA of Cited Violation:
HL&P concurs with example IA of the cited violation.
III. Reason for Violation:
on May 03, 1991, Service Request (SR) SG-115643, which was initiated to repair boric acid leakage bolts 3, 5,
and 14 on Steam Generator 1B, was voided.
The work activity for SG-115643 was to be performed on SG-115696.
The additional scope of work was noted on SR SG-115696.
SG-115696, originally scheduled for Unit 1 Fourth Refueling Outage (1RE04), was rescheduled.
Personnel rescheduling the work were unaware of the additional scope transferred from the voided SR SG-115643.
IR\\93-137.001
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Attachment ST-HL-AE-4467 Page 2 of 5 Revised Reply to Notice of Violation 9314-02 IV.
Corrective Actions:
The boric acid leaks were corrected under SRs SG-158293 and SG-179924.
The Work Management System (WMS) entry for SG-115696, a recurrent SR to perform plant maintenance on the steam generator during outages, has been updated to include the additional work scope of the voided SG-115643.
A Maintenance Planning Training Bulletin was issued May 21, 1993, that addresses the correct process of voiding Service Requests and changes / additions to the scope of existing Service Requests.
Individual Maintenance Planning Training for all Maintenance Planning personnel has been initiated addressing guidance / direction for voiding Service Requests and changing / adding scope to existing Service Requests.
This individual training shall be completed for existing personnel on June 15, 1993.
As personnel are added to the Maintenance Planning Division, individual training on this subject will be administered as part of the indoctrination training to the Division.
Maintenance Planning personnel will be periodically trained on-this subject of voiding Service Requests and changing / adding scope to existing Service Requests as part of the Maintenance Planning Continuation Training Program.
V.
Date of Full Compliance:
HL&P is in full compliance.
VI.
Houston Lichtino & Power Position in ExamDle IB of Cited Violation:
HL&P does not concur with example IB of the cited violation.
HL&P does not consider that the data constituted a nonconforming condition.
As such, no further remedial or corrective action was deemed necessary.
IR\\93-137.001
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i Attachment ST-HL-AE-4467
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Page 3 of 5 i
e Revised Reply to Notice of Violation 9314-02 VII. Basis For Disputina Example IB of Cited Violation:
During Unit 1 First Refueling Outage (1RE01), the primary
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manway closure stud elongation was measured using digital depth micrometers.
Following the outage, the digital depth micrometers were decontaminated and returned to the Metrology Laboratory (MET Lab) for scheduled calibration.
The instruments were found corroded and calibration was impossible.
A Metroloav Laboratory Evaluation Form was generated to document the condition of the instruments, the lack of "as found" data, and the action required.
A Service Request (SR) 128151 was initiated to verify the as-left stud elongation measurements on SGs 1A, 1B, 1C, and 1D during the Unit 1 Second Refueling Outage (1RE02).
Since the originating problem was identified on the Met Lab Evaluation Form, a SR was selected to track and document this action.
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During 1RE02, stud elongation measurements were taken on all primary manway closure studs as required by SR 128151.
Two sets of stud elongation measurements were requested by Plant Engineering Department (PED), one using a standard depth
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micrometer and the second using a digital depth micrometer.
l The results were to be reported to PED for an engineering evaluation.
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The two sets of elongation measurements yielded data which was
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not comparable to the 1RE01 as-left stud elongation
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measurements since they showed an apparent growth.
However,
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the original (1RE01) stud elongation data was evaluated by Engineering and was deemed to be acceptable, and no further
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action was required based on:
1RE01 relaxed stud length (baseline) measurements were e
considered questionable since the instruments used did not receive a post calibration and the 1RE02 as-found measurements showed an apparent increase in stud lengths.
Stud elongation is not possible without additional force e
applied.
1RE01 total elongation values (difference of the relaxed e
stud length and tensioned length) were considered correct.
IR\\93-137.001
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Attachment ST-HL-AE-4467 Page 4 of 5 Revised Reply to Notice of Violation 9314-02 VII. Basis For Discutina ExamDie IB of Cited Violation: (Cont'd)
Variables that affect stud elongation (stud temperature e
and primary system pressure and temperature) were not recorded nor controlled during 1RE01 or 1RE02.
Stud temperature affects the relative lengths of the stud and the internal rod as a result of the different thermal expansions of these materials.
Primary system pressure affects the magnitude of the forces exerted on the studs ar.d changes the stud length.
Primary system temperature affects the stud temperature.
Therefore, measurements taken at atmospheric pressure will vary from measurements taken with the primary system pressurized.
In March, 1993, the NRC staff reviewed c > t.es of elongation data compiled from 1RE01 through 1RE04.
Irom that review, the NRC staff concluded that there was an apparent growth in stud length to the point of plastic deformation.
The NRC staff requested HL&P to justify the acceptability of the studs prior to the Unit 1 startup.
HL&P provided justification for the acceptability of the studs during a conference call on March 26, 1993.
This justification included an evaluation of the original 1RE01 relaxed stud length data, a calculation of the elongation necessary to exceed minimum yield, an evaluation of the stud tensioning equipment capability to plastically deform the studs, and the result of the standard go/no-go gauge tests.
This justification included the following points:
The original 1RE01 data was approximately 0.004 inches
shorter than data obtained in 1RE02.
Data taken in February, 1993, indicates that there is good corroboration with the 1RE02 measurements.
The original baseline measurements taken in 1RE01 probably do not represent the actual dimension.
However, these values do provide the correct magnitude of the distance from the top of the stud to the internal rod.
An engineering calculation determined that a total i
e elongation of 0.0241 inches would be required to reach the minimum stud yield stress.
A comparison of the relaxed stud length data to the 1RE02 elongation measurements, shows that no studs were stressed beyond yield.
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i Attachment ST-HL-AE-4467 Page 5 of 5 Revised Reply to Notice of Violation 9314-02 VII. Basis For Disputina Example IB of Cited Violation: (Cont'd)
The equipment and procedures used to tension the studs i
e were evaluated for the capability to stretch the studs beyond the minimum yield stress.
Using conservative assumptions, the maximum stretch the equipment could produce was 0.0167 inches which is below the 0.0241 inches required for minimum yield.
Therefore, the equipment capacity and procedure guidelines preclude the studs from being stretched beyond yield.
The result of the standard go/no-go gauge tests were e
evaluated and all but three passed these tests satisfactorily.
All studs exhibited elastic behavior when detensioned.
When the manway closure was assembled, the studs were retensioned successfully.
Pursuant to the criteria of 10CFR50, Appendix B, Criterion XVI, HL&P considers that established measures were used to assure that the condition was promptly identified and corrected.
The lack of "as-found" calibration data for the digital micrometers was identified in the Met Lab Evaluation Form and action to reverify the as-left measurements was performed.
HL&P Engineering reviewed the stud elongation data and concluded that the stud elongation was acceptable and that the as-left measurements from 1RE01 were not comparable to the 1RE02 as-found measurements.
Reevaluation of the data in March, 1993, reaffirms that the decisions made and conclusions reached in 1RE02 were correct and demonstrate a sound engineering basis.
Therefore, no nonconformance existed and no additional evaluation nor documentation was required.
SR 128151 documented the stud elongation data and the Engineering conclusion.
IR\\93-137.001