IR 05000498/1993027

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/93-27 & 50-499/93-27 on 930916

ML20059A106
Person / Time
Site:	South Texas
Issue date:	12/20/1993
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
NUDOCS 9312300015
Download: ML20059A106 (5)

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UNITED STATES -

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611 RYAN PLAZA DRtVE, SUITE 400 4 AR LINGTON, T E XAS 76011 8064

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DEC 2 0 Eg3 Dockets: 50-498 50-499 Licenses: NPF-76 '

NPF-80 Houston Lighting & Power Company ATTN: William T. Cottle, Group

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Vice President, Nucitar P.O. Box 289 Wadsworth, Texas 77483

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SUBJECT: NRC INSPECTION REPCRT 50-498/93-27; 50-499/93-27 Thank you for your letter of November 19, 1993, in response to our ,

letter dated September 16, 1993, in which you were requested to respond to the negative findings identified in the NRC Inspection Report 50-498/93-27; 50-499/93-27. We have reviewed your reply and find it responsive to the concerns raised in our letter. We will review the implementation of your stated actions during a future inspectio

Sincerely, (:

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Samuel ollins, Directo Division , Reactor Safety cc:

Houston Lighting & Power Company ATTN: James J. Sheppard, General Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483

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280005 9312300015 931220 i ;

PDR ADDCK 05000498 I O PDR l _I

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Houston. Lighting and Power Company -2-City of Austin Electric Utility Department ATTN: J. C. Lanier/M. B. Lee 721 Barton Springs Road Austin, Texas 78704 City Public Service Board ATTN: K. J. Fiedler/M. T. Hardt '

P.O. Box 1771 '

San Antonio, Texas 78296 Newman & Holtzinger, P. ,

ATTN: Jack R. Newman, Es ; 1 1615 L Street, NW Washington, D.C. 20036 Central Power and Light Company  ;

ATTN: G. E. Vaughn/T. M. Puckett P.O. Box 2121 i Corpus Christi, Texas 78403 i

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INP0 i Records Center 700 Galleria Parkway li Atlanta, Georgia 30339-5957 Mr. Joseph M. Hendrie 50 Bellport Lane Bellport, New York 11713 Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, Texas 78756 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 Licensing Representative Houston Lighting & Power Company Suite 610 Three Metro Center Bethesda, Maryland 20814

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Houston Lighting and Power Company -3- '

Houston Lighting & Power Cr spany ATTN: Rufus S. Scott, A .ociate General Counsel P.O. Box 61867 Houston, Texas 77208

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bec to DMB (IE01) ,

bec distrib. by RIV:

J. L. Milhoan Resident Inspector Section Chief (DRP/A) Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS ,

RIV File .

Project Engineer (DRP/A)

R. Bachmann, OGC, MS: 15-B-18 Section Chief (DRP/TSS) ,

D. Powers L. Ellershaw

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RIV: RI :P',* C:MS* DD:DRS n / D:DRPn [ D:DRSd LEEllershaw DAPowers ATHowell ABBeach SJColliks

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Houston Lighting and Power Company -4-bec to DMB (IE01)

bec distrib. by RIV:

J. L. Milhoan Resident Inspector Section Chief (DRP/A) Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer (DRP/A)

R. Bachmann, OGC, MS: 15-B-18 Section Chief (DRP/TSS)

D. Powers L. Ellershaw

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RIV:RI:MS* C:MS* DD:DRS f, ,/ D:DRPn g D:DR$d, LEE 11ershaw DAPowers ATHowell ABBeachfF SJColl[

/ /93 / /93 /)/2993 9 [13 /93 M /20/93

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12/16/93 09:02 001

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The Light c" e map a ny South Tczas Project Electric Geocrating Station P. O. Box 289 Wadsworth,Tewas 77483 Houston L1 5 h'ia5 & P""

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Post-R" brand tax transmittal memo 7671 November 19, 1993 Sfu/' 4,d , y s " "/Sh M err ( I ST-HL-AE-4630

g3 c" jj p File No.: G02.04.01

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"" *f/ 7 f o o [.27 f ["# aucAcar newua.acory comma.ssion Attention: Document Control Desk wachington, DC 20555 South Texas Project Units 1 and 2 Docket Nois. STN 50-498; STN 50-499 Response To Inspection Report (IR) 50-498/93-27; 50 499/93-27 Reliability and Operability of Satety-Related Check Valves liouston T.ighting and Power Company (HL&P) submits the encloced attachment as the response to the negative inspection findinge in the Results section of Inspection Report listed (IR) 50-499/93-27; 50-499/93-27, conducted August ~23-27,(STPEGS), 1993 at the South Texas Project Electric Generating Station Units 1 and 2. The areas examined during the inspection dealt with the STPEGS program for assuring the the effectiveness of reliability and operability of safety-rclated check valve Should you have any questions on this subject, please contact 7'7 Mr. Ray Pate at (512) 972-7787 or me at (512) 972-878 /

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HRP/eg b . . .s~ l Attachment- Response Lu IR 93-27 Weaknessoa

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Housam T.lghting Ar Pwer Company ST HT. AF.-4630 South Texas Project Electric Generating Station File No.: G02.04.01 Page 2

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Regional Administrator, Region IV Rufus S. Scott U. .S. 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 Conunission Institute of Nuclear Power Washington, DC 20555 13H15 Operations - Records Center !

700 Galleria Parkway David P. Loveless Atlanta, GA 30339-5957 Sr. Resident Tnspector c/o U. S. Nuclear Regulatory Com Dr. Joseph M. Hendrie P. O. Box 910 50 Dellport Lane Bay City, TX 77404-910 Bellport, NY 11713 .,

6 Newman, Raquire K. Lacker Newman & Holtzinger, P.C., STE 1000 Bureau of Radiation Control t 1015 L Street, Texas Department of Health i Washington, DC 20036 1100 West.49th Street Austin, TX 78756-3189 ,

K. J. Fiedler/M. T. Hardt *

City Public Service C. Nuclear Regulatory Conu P. O. Dox 1771 Attn: Document Control Deck San Antonio, TX 78296 Washington, i C. Lanier/M. B. Lee City of Austin Electric Utility Department 721 Darton Springs Road Aust.in. TX 70704 G. E. Vaughn/T. M. Puckett Central Power and Light Company P. O. Box 2121 Corpus Christi, TX 7840T

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ATTACHMENT

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RESPONSE TO INSPECTION REPORT 93-27 WEAKNESSES *

'i "A formal check valve program did not exist, but one was  :

being developed'(section 2.2).-

Ilouston Lighting and Power Company (ITL&P)' has developed . ,

procedure OPEP01-ZA-0003, check Valve Reliability Progra l This procedure was approved on October 29, 1993'and became effective on November 01, 1993. This program document -

includes the following key elements: '

- Program scope and objectives

- Delineates responsibilities and program interfaces

- Specifies tracking and trending methods  ;

- Defines the roles of intrusive and non-intrusive testing

- Sets guidelines for including and excluding valves from '

the program

- Defines the Check valve Index and Database and their >

scope l "There was no formal or documented coordination established between the check valve program coordinator and other groups whose activities could affect the check valve program (section 2.2)."

HL&P identified that procedure OPGP03-ZE-0031, Design Change ImplemenLation, did not reference Lhe Check Valve j Inde The Design Change Checklint, form OPGP03-ZE-0031-1, of procedure OPGP03-ZE-0031, has been revised and now lists the procedure OPSP11-ZE-0001, Check Valve Inspection Program, in the Program Impact section of the form so that design changes are reviewed for potential .i check valve programmatic impact . "The identity of check valve program valves was maintained in a data base that was not named, or approved >

(Section 2.2)."

The Check Valve Index, available under necords Management "

System (RMS) file.: Prefix: INVN FILE #:Z1514, as referenced in OPSP11-ZE-0001, Check valve Inspection '. ;

Program, is the controlled listing of the valves in the progra There were several valves which needed to be I added to the indices. The valves were added and the  !

indices updated and approved on October 29,'1993. The i check valve Database that was reviewed by the inspectors li n unvi t.t s as

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was under development. Plant Engineering Department (PED) l plans to continue development and maintain the database as' '

a working database. The minimum scope of the database  ;

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will be defined in Check Valve Inspection Program, exi clearly identified as a working database and not.as a proceduralized document. The database will include all:

the valves in the check valve Inspection Program and a group of valves outside the scope of the program which are being monitored for repeat maintenance and failure Inspections may be performed on valves in this group'in j conjunction with corrective maintenance activitie . " Errors pertaining to inspection frequencies axisted between the Unit 1 and Unit 2 check valve data bases (section 2.2)."

The Check valve Index is the controlled 31st of the valves ;

in the inspection program and their respective inspection ,

frequencie There are no inconsistencies between Unit 1 and Unit 2 indices. The database reviewed by-the inspectors was under developmen ' "A check valve monitoring activity'(1.e., non-intrusive +

examination methods) had been established, but not *

implemented (section 2.2)." q

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The non-intrusive check valve test equipment has been calibrated and is presently being utilized in the Unit PED has collected full acoustic alguatures on ten (10)

valvns tn dat . "A lack of conservatism in engineering judgement and an apparent imprecision in the input data may have resulted in an inaccurate determination of those check valves most vulnerable to structural deterioration (Section 2.3)." (

The observations are technically correct, however, D Paul Tullia, a nationally recognized check valve expert from Utah _ State UniversiLy W.ater Research Laboratory, states "measuremento of the actual parts in service obviously provide the most reliable information regarding actual wear rates. Whenever practically possible, this data should be used to refine future wear predictions and to determine suitable maintenance intervals." The inspector performed a detailed review on the analysis ui '.

the Feedwater check valve PED has seviewed the inspection histories of other check valves in the program, naned on this review of internal inr.pections, PFD has '

found no reason to question the conservatism of the Kalsi repor In neveral instancen. the inspection interval has i

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SP-H[r-AE-4630 Page-3 of 3 l been lengthened beyond the original Kalsi recommendation due to lack of wear revealed by these inspections. While

there may be some non-conservative assumptions and imprecise data in the Kalsi report, the empirical resultu l'

have not challenged the report conclusions-and the risk of L future challenges is sufficiently low such thac performing

!~ the analysis again is not warrante : "The inspectors identified instances in which check valves l

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failed local leak rate testing and the licensee apparently did not perform any root cause analysis (section 2.4)."  ;

The five instances of LLRT' failure identified by the f inspectors were all Dual Disc check-Valves (DDCV).. A copy 1

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of the HL&P modification to the DDCV was provided to the I

inspectors. The inspectors acknowledged that the DDCV l

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design has been a problem in the industry for a number of '

years. A Station Problem Report (SPR), SPR # 890071, was

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written in January, 1989 when Unit 2. valve CC0058 failed Lhe Local Lenk Rate Test (LLRT). One corrective action for the SPR was the hinge modification reviewed by the '

l inspectors. A root cause analysis of the failure was .

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l performed, The root cause of this failure'was attributed l to * excessive clearance existing between the hinge and the

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l hinge pin a31owing the valve disc to lift off the' seat."

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The valve hinge design was the root cause. The design ,

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problem was corrected by installing shims in the hinges to .

l ullow the valves to close and seal properly. The modification is installed when a valve is identified with

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excessiva lenkag The Maintenance IIistories of the five subject valves have been corrected to clearly identify.the root cause of the  ;

failure '

, Trending procedures, methodology, or criteria had not yet been established with respect to the check valvo program '

l (section 2.5)."

l-l IIL&P has addressed trending, methodology, and criteria in !

procedure OPEP01-ZA-0003, Check Valve Reliability Program f refe.renced in item :

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