IR 05000498/1998001

Refers to in Which Licensee Denied Two Violations of 10CFR50.65 Noted in NOV Issued on 980616.For Violations 50-498/98-01 & 50-499/98-01,NRC Position Remains That Digital Rod Position Sys Required in Scope of Maint Rule

ML20154H283
Person / Time
Site:	South Texas
Issue date:	10/05/1998
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
50-498-98-01, 50-498-98-1, 50-499-98-01, 50-499-98-1, EA-98-322, NUDOCS 9810140134
Download: ML20154H283 (5)

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cJ # UNITED STATES y  ; NUCLEAR REGULATORY COMMISSION f REGloN Iv 611 RYAN PLAZA DRIVE, SUITE 400

,,,,o ARLINGTON. TEXAS 760118064 October 5,1998 EA 98-322 William T. Cottle, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-498; -499/98-01 AND DENIAL OF NOTICE OF VIOLATION

Dear Mr. Cottle:

This is in reference to your letter dated July 21,1998, in which you denied two violations of 10 CFR 50.65," Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Your letter was in response to a Notice of Violation issued June 16,1998, in conjunction with NRC Inspection Report 50-498; -499/98-01.

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in regard to Violation 50-498; -499/9801-01 that cited the failure to include the digital rod position indication system into the scope of the Maintenance Rule Program, you stated that you still believe that the digital rod position indication system is not required to mitigate accidents and should not be included as an example in this violation. However, you stated that station management decided to add this system to the Maintenance Rule program based on the NRC position it remains NRC's position that the digital rod position indication system is required to be included in the scope of the Maintenance Rule because it provides an assessment function and is an integral portion of the mitigation function. A primary operator action taken during use of emergency operating procedures is to use this system to determine whether control rods are

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fully inserted and adequate shutdown margin has been achieved. We will review your corrective actions related to Violation 50-498; -499/9801-01 during a future inspection.

Your response also denied Violation 50-498; -499/9801-03; This violation involved the failure to establish adequate measures to evaluate the appropriateness of the performance of preventive maintenance for the solid state protection system. Specifically, you had no perfonppnce measures established for availability of the solid state protection system. In denying Violation 50-498;-499/9801-03, your letter referenced the guidance of NUMARC 93-01,

" Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Revision 2, Section 12.2.4, " Optimizing Availability and Reliability for SSCs." You also stated in L Letter NOC-AE-000230, dated July 21,1998, that an unavailability sensitivity study using the l South Texas Project Probabilistic Risk Assessment demonstrated that solid state protection system logic train unavailability has negligible impact on plant risk (i.e., core damage frequency).

9810140134 981005 r PDR ADOCK 05000498 G PDR

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STP Nuclear Operating Company -2-Section 12.2.4 of NUMARC 93-01 provides several ways to meet the requirements of 10 CFR 50.65(a)(3). Your denial was based on each of the following examples for meetir ,9 the balancing requirement provided in Section 12.2.4, which included:

Ensuring that appropriate preventive maintenance is performed to meet availability objectives as stated in plant risk analysis, Final Safety Analysis Report, or other reliability approaches to maintenance;

Allocating preventive maintenance to applicable tasks commensurate with anticipated performance improvement;

Reviewing to determine that availability of structures, systems, or components has been acceptable;

Focusing maintenance resources on preventing those failure modes that affect a safety function; or

Scheduling, as necessary the amount, type, or frequency of preventive maintenance to appropriately limit the time out of service.

On September 16,1998, a telephonic conference call was held to further discuss your position on the solid state protection system (i.e., not monitoring unavailability). During that conference call, your staff stated that STP was meeting the intent of NUMARC 93-01, Section 12.2.4. " Optimizing Availability and Reliability for SSCs." Specifically all five recommended approaches to balancing availability and reliability were addressed as part of your program. Your staff also stated that an unavailability sensitivity study using South Texas Project's Probabilistic Risk Assessment, which demonstrated that the solid state protection system logic train unavailability has negligible impact on plant risk (i.e., core damage frequency) had been performed. This information was not specifically reviewed and assessed during our inspection. Accordingly, NRC Violation 50-498; -499/9801-03 will be reclassified as Unresolved item 50-498; -499/9801-03 until the NRC staff further reviews the following items: (1) How you meet the intent of NUMARC 93-01, Section 12.2.4, " Optimizing Ave!! ability and Reliability for SSCs," for this system and potentially other systems; and (2) the sensitivity study discussed above, specifically with respect to the assumed surveillance testing hours for unavailability for the solid state protection system. These issues will be reviewed during a subsequent followup inspection. !y in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

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STP Nuclear Operating Company -3-If you have any questions regarding this matter, please contact Dr. Dale Powers at 817/860-8195.

Sincerely,

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hj,1bll.9 j James E. Dyer Deputy Regional Administrator Docket Nos.: 50-498;50-499 License Nos.: NPF 76; NPF-80

! Enclosure:

Supplemental Information l cc:

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~ Lawrence E. Martin, Vice President

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l Nuclear Assurance & Licensing i L

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STP Nuclear Operating Company P.O. Box 289

. Wadsworth, Texas 77483 l

A. Ramirez/C. M. Canady City of Austin  !

- Electric Utility Departnent 721 Barton Springs Road Austin, Texas 78704 l

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l Mr. M. T. Hardt/Mr. W. C. Gunst City Public Service Board

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P.O. Box 1771 San Antonio, Texas 78296

- D. G. Tees /R. L. Balcom L

Houston Ughting & Power Company ,) y

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P.O. Box 1700 l

Houston, Texas 77251 l

, Jon C. Wood l Matthews & Branscomb One Alamo Center 106 S. St. Mary's Street, Suite 700 i- ' San Antonio, Texas 78205-3692

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STP Nuclear Operating Company -4-Jack R. Newman, Esq.

Morgan, Lewis & Bockius 1800 M. Street, N.W.

+ 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 Bureau of Radiation Control State of Texas

' 1100 West 49th Street Austin, Texas 78756 Mr. Jim Calloway Texas Public Utihti Commission William B. Travis Building 1701 North Congress Avenue P.O. Box 13326 Austin, Texas 78701-3326 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Judge, Matagorda County Matagorda County Courthouse a ;,

1700 Seventh Street

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Bay City, Texas 77414

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o 4 STP Nuclear Operating Company -5-bec to DCD (IE01)

bec distrib. by RIV:

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)

M. Satorius, (OE) (EA 98-322) -

RIV Al 98-301 (CGordon)

RIV Al 98-301 (CGoines)

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100011 4r g DOCUMENT NAME: g:\ reports \ST801 AK.CEJ To receive copy of document, indicate in box: *C" = Copy without enclosures "E" = Co)y with ,tsclosures f "N" = No co i ay RIV:SRl:MB SRl:MB NRR,,,l y/ p:MB D:[$ @ l DRA CEJohnson/imb* PCGage* SCBlWI, if VDAPowers* ATHowell JEDye@

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ENCLOSURE

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SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee

T. Bowman, Assistant Unit 1 Operations Manager i J. Crenshaw, Division Manager, Mechanical System Engineering S. Head, Supervisor, Licensing .

I T. Jordan, Department Manager, System Engineering M. Lashley, Division Manager, Reliability Engineering A. Moldenhauer, Staff Engineer, Probability Risk Assessment Group

' M. Murray, Section Supervisor, l&C Engineering R. Riccio, Solid State Protection System Engineer T. Stroschein, Section Supervisor, Component Reliability J. Winters, Maintenance Rule Coordinator

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l NRC P. Balmain, Office of Nuclear Reactor Regulation S. Black, Office of Nuclear Reactor Regulation R. Correia, Office of Nuclear Reactor Regulation E. Ford, Office of Nuclear Reactor Regulation P. Gage, Senior Reactor Inspector A. Howell Ill, Director, Division of Reactor Safety-C. Johnson, Senior Reactor inspector D. Powers, Chief, Maintenance Branch ITEMS OPENED AND CLOSED Ooened 50-498;-499/9801-03 URI Failure to adequately monitor the solid state protection system and other risk significant electrical and instrumentation and control SSCs.

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Closed

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50-498;-499/9801-03 VIO Failure to adequately monitor the solid state protection system.