IR 05000498/1997018
| ML20217F173 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/03/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| 50-498-97-18, 50-499-97-18, NUDOCS 9710070385 | |
| Download: ML20217F173 (5) | |
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SUBJECT:
RESPONSE TO NRC INSPECTION REPORT 50-498/97-18;50-499/97-18
Dear Mr. Cottle:
Thank you for your letter of September 25,1997, in response to our t.u mt 27, 1997, letter and Notice of Violation concerning the approval of a replacement steam generator pressure boundary material that was not permitted by the governing specification. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sine ly, rthur T.
oweli 111, Dire'ctor Division o ctor Safety Docket Nos.: 50-498;50-499 License Nos.: NPF-76; NPF-80 cc:
Lawrence E. Martin, General Manager
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Nuclear Assurance & Licensing Houston Lighting & Power Company P.O. Box 289 Wadsworth, Texas 77483 ffflllll'lllla!!ltblfff ff 9710070385 971003 PDR ADOCK 05000498
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' P.O. Box 1771 San Antonio, Texas 78296 Jack R. Newman, Esq.
1800 M. Street, N.W.
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Washington, D.C. - 20036 5869 Mr. G. E. Vaughn/Mr. C. A. Johnson Central Power & Light Company P.O. Box 289 -
Mail Code: N5012 Wadsworth, Texas 77483-INPO-
- Records Center 700 Galleria Parkway
- Atlanta, Georgia -30339-5957 Dr. Bertram Wolfe 15453 Via Vaquero
- Monte Sereno, California 95030 -
Bureau of Radiation Control-State of Texas 1100 West 49th Street Austin, Texas 78756 Mr. Glenn W. Dishong Texas Public Utility Commission 7800 Shoal Creek Blvd.
Suite 400N Austin, Texas 78757-1024.
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Bey City, Texas 77414 Licensing Repreisntative
Houston Lighting & Power Company Suite 610'
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-Joseph R. Egan, Esq.
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Egan & Associates,LP,C.
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E-Mail report to Document Control Desk (DOCDESK)
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Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
R. Bachmann, OGC (MS: 15-B-18)
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d The Light company Ifouston Lighting & Power South Texa. Project Electric Generating Station P. O. Box 289 Wadsworth. Texas 77483 i
September 25,1997
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File No.: GG2.04.02
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30W 10CFR50 App B
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U. S. Nuclear Regulatory Commiss on J
Atter. tion: Docurnent Contrca Desk ~ --
Washington, DC 20555
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g South Texas Project Unit 1 Docket No. STN 50-498 Reply to Notice of Violation 9718-01 South Texas Project has reviewed Notice of Vic!ation 9718-01, dated August 27,1997, and submits our reply in Attachmel.t 1. The event described in the Notice of Violation did not have an adverse effect on the health and safety of the public.
The Notice of Violation transmittal letter requested that comctive actions taken by Westinghouse to resolve a potential ASME Code violation be furnished with our response.
Attachment 2 provides the requested information.
South Texas agrees with the inspection report that our efforts could be improved in the area of oversight planning and will issue a more definitive approach to inspection planning by October 1,1997. Additionally, written instructions have been issued to engineers assigned to coordinate and oversee Westinghouse engineering activities in Monroeville and Pensacola.
The inspection report also identified an inspection followup item regarding compliance with ASTM E23 and ASTM E208. South Texas is current'v nssembling documentation to demonstrate compliance and will have the data ready by October 30,1997.
If there are any questions regarding this reply, please contact Mr. John Conly at (512) 972-7019 or me at (512) 972-7162.
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S. E. Thomas Manager, Design Engineering JTC/
Attachments:
1.
Reply to Notice of Violation 9718-01 2.
Resolution of Potential ASME Code Violation
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97-l E 01 Projeu Manager on Behalf of the Participant, in the %uth 'lesa, Projca t
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- Houston Lighting & Power Company South Texas Project Electric Generating Station ec:
Ellis W. Merschoff Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U. S, Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 4:00 P. O. Box 61067
_ Arlington,TX 76011-8064 Houston,TX 77208
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Thomas W. Alexion-Institute of Nuclear Power Operations Project Manager, Mail Code 13H3 Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 David P. Loveless Richard A. Ratliff
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Senior Resident Inspector Bureau of Radiation Control U. S. Nuclear Regulatory Commission Texas Depaitment of Health P. O. Box 910 1100 West 49th Street Bay City,TX-' 77404-0910 Austin,TX 78756 3189 J. R. Newman, Esquire Dr. Bertram Wolfe
~ Morgan, Lewis & Bockius 15453 Via Vaquero
- 1800 M Street, N.W.
Monte Sereno, CA 95030 Washington, DC 20036-5869 M. T. I;ardt/W, C. Gunst J. R. Egan, Esquire City PuMic Service Egan & Associates, P. C.
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P. O. Box 1771
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2300 N Street, N.W.
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- San Antonio,TX 78296 Washington,DC 20037
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J. C. Lanier/M. B. Lee U. S. Nuclear Regulatory Commission-City of Austin Electric Utility Department Attention: Document Control Desk -
721 Barton Springs Road Washington, DC 20555-0001 Austin,TX 78704 -
Central Power and Light Company Attention: G. E. Vaughn/C. A. Johnson
' P. O, Box 289, Mail Code: N5012 -
Wadsworth,TX 77483 e
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Attachment I
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ST-IIL-AE 5754 Page 1 of 2 Reply to Notice of Violation 9718 01 I.
Statement of Violation Criterion III of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis... for those structures, systems and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions...."
Criterion V of Appendix B to 10 CFR Pan 50 requires that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Paragraph 304.11.1 of Specification 4R129NS1014, " Specification for Replacement Steam l
Generators," Revisicn 0, states, in part, "... Channel head, tubeside and shellside pressure boundary materials shall be limited to SA 533 GrB Class 1 plate and SA 508 Class 3A forgings... "
Contrary to the above, Westinghouse Purchase Order E 52891 and attached Material
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Specification A533C07, "SA-533 Type B Class 2 Plate (Section III-NB)," which were applicable to the procurement of Unit I replacement steam generator upper shells, were approved by your Letter ST-W2-HS-000040 dated June 4,1996, without concurrent revision of Specification 4R129NS1014 to reflect the design change to a different pressure boundary plate material from that originally approved.
This is a Severity Level IV violation (Supplement I) (50-498/9718-01).
II.
South Texas Project Position South Texas Project concurs that the violation occurred with the following clarification. For the replacement steam generators, Westinghouse is responsible for design control under 10CFR50 Appendix B Criterion IU, while South Texas is responsible for control of purchased material, t
equipment, and services under Criterion VII.
l III.
Reason for Violation The reason for this violation was the preparer's and cognizant reviewers' lack of thorough review of the detailed replacement steam generator contract technical requirements documents against the Westinghouse material specification prior to release. In developing its specification and procurement package for fabrication of the upper shells, Westinghouse failed to conform its
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ST-ILAE-57 4 Page 2 of 2
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design document to the applicable higher tier contract technical requirements documents. Dunng its review of the Westinghouse procurement package and material specification, South Texas did
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not detect the difference between the Westinghouse documents and the replacement steam generator contract technical requirements documents.
IV.
Corrective Actions 1. The Replacement Steam Generator Specification will be revised to show the correct plate material by October 16,1997.
2.-- A memo was issued to Westinghouse Pensacola project engineering personnel describing this violation and reemphasizing their responsibility to meet the specification through
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careful review of the mquirements and proper translation of those requirements into Westinghouse technical documents.
3. A review to identify similar errors in Westinghouse implementation of purchase specification requirements will be completed by September 30,1997. The South Texas Pmject Corrective Action Program is being used to capture specification deficiencies.
l 4. A guideline defining expectations for technical reviews by South Texas engineers was distributed to ensure that steam generator replacement project reviewers understand management expectations for depth of review.
5. Training will be conducted for South Texas replacement steam generator project personnel who may review and approve vencior document submittals. The training will
- include management review expectations and will emphasize the importance of consulting technical requiremems when performing these reviews. The training will be complete by October 30,1997.--
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Date of Full Compliance South Texas Project is in full compliance.
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Attachment 2
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ST-IIL AE 5754 Page 1 of 2'
Corrective Actions to Resolve a Potential ASME Code Violation NRC Statement
' "...during review of the Ansaldo certification for the upper shell courses, the inspector observed that the reponed magnetic particle examination data appeared to not conform to ASME Section V Code prod amperage requirements. Specifically, Article 7, paragraph T 743.2 of ASME Section _V Code requires an amperage range of 100-125 amperes per inch of prod spacing be used for conducting magnetic particle examinations of section thicknesses 3/4 inch and greater.
Ansaldo was required by Westinghouse Drawing 6488E61 to perform a magnetic particle examination of the longitudinal weld joint preparation rurfaces, the dressed root of the initia'
weld prior to completion of the weld from the second side, and the final post weld heat treated
. surfaces. During review of Test Report 11581 dated January 15,1997, which pertained to magnetic particle examination of the root of a "J" shell (Item 006, Purchase Order E52891)
longitudinal weld seam after grinding, the inspector observed that the recorded amperage and a
prod spacing values were, respectively, ~ 1000 amperes and ~ 180 mm. The maximum amperage pemlitted by the ASME Section V Code for this prod spacing was calculated by the inspector to
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.be 886 amperes. The uw of-1000 amperes for the examination thus appeared to exceed ASME Section V Code requirements The inspectorreviewed the magnetic particle examination test report for the weld joint preparation surfaces for the "J" shell course and the corresponding test reports for the "H" shell course, and noted the same recorded values for amperage and prod
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spacing..."
Root Cause Ansaldo's practice during the time of the fabrication of all upper shells for Westinghouse was to report approximate amperage values rather than actual values. This ustomary practice was the root cause of the apparent Code nonconformance.
Corrective Actions
. Ansaldo has committed to annotate actual amperage values in the future.
. AdditionalInformation
' A number of data points exist to provide reasonable assurance that magnetic particle testing was performed within established limits. Ansaldo's test procedures have been reviewed by and demonstrated to Ansaldo's Authorized Nuclear Inspector. They have been reviewed by wre-o s.- em m a m**
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ST-HL-AE-5754 Page 2 of 2 Westinghouse and South Texas personnel, confirming that the established test parameters comply with ASME Code requirements. A member of the South Texas procurement quality team traveled to Ansaldo in mid-1997 to observe activities and equipment. As part of that visit, he witnessed magnetic particle testing and confirmed that the tests were performed in accordance with established parameters.
That confrience notwithstanding, the potential still exists that testing other than that physically observed could have been performed outside Code parameters. South Texas and Westinghouse personnel visited Ansaldo in August 1997 to investigate a worst-case scenario. At an actual prod spacing of six inches (less than the approximate spacing on the test reports) and an actual amperage of 990 (the test reports list an approximate amperage of 1000), it was confirmed that, even had the test been performed using excessive amperage, there was no loss of sensitivity with the thickness of the material and any material defects would have been adequately exhibited.
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In conclusion, South Texas agrees that the practice of entering approximate test parameters into test reports is not a good practice, particularly when the approximate values exceed those permitted by the Code. Ansaldo has been instructed to and has committed to annotate actual values in the future. Based on the previously established confidence and the results of the worst-case scenario investigation, no further action is planned related to tests already performed.
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