ML20044G829
| ML20044G829 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/25/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9306040325 | |
| Download: ML20044G829 (5) | |
See also: IR 05000498/1993036
Text
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UNITED ST ATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE,3UITE 400
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AR LINGTON. T E XAS 760114064
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MAY 251993
Dockets:
50-498
50-499
Licenses: NPF-76
NPF-80
Houston Lighting & Power Company
ATTN: William T. Cottle, Group
Vice President, Nuclear
P.O. Box 1700
Houston, Texas 77251
SUBJECT: NRC INSPECTION REPORT NO. 50-498/92-36; 50-499/92-36
Thank you for your letter of May 11, 1993, which provides supplemental
information to your letter of April 2,1993, which responded to our letter and
Notice of Violation dated March 5, 1993. We have reviewed the information and
your proposed change to your commitment to revise procedures associated with
your ASME Section XI testing program and find it acceptable. We note that
your recent efforts to improve the corrective action program appear to have
been successful in this instance; the problem was identified and prompt
measures to prevent recurrence were initiated. We will further review the
implementation of your corrective actions during a future inspection to
determine whether full compliance has been achieved and will be maintained.
Sincerely,
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Bill Be ? . Director
Division of Reactor Projects
cc:
(see next page)
9306040325 930525
ADDCK 05000498
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Houston Lighting & Power Company
-2-
cc:
Houston Lighting & Power Company
ATTN: William J. Jump, 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
City Public Service Board
ATTN:
R. J. Costello/M. T. Hardt
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:
D. E. Ward /T. M. Puckett
P.O. Box 2121
Corpus Christi,. Texas 78403
Records Center
700 Galleria Parkway
Atlanta, Georgia 30339-5957
Mr. Joseph M. Hendrie
50 Bellport Lane
Bellport, New York 11713
Bureau of Radiation Control
State of Texas
1101 West 49th Street
Judge, Matagorda County
Matagorda County Courthouse
1700 Seventh Street
Bay City, Texas 77414
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Houston Lighting & Power Company
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Licensing Representative
Houston Lighting & Power Company
' Suite 610
Three Metro Center
Bethesda, Maryland 20814
Houston Lighting & Power Company
ATTN:
Rufus S. Scott, Associate
General Counsel
P 0. Box 61867
Houston, Texas 77208
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J. L. Milhoan
Resident inspector
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Section Chief (DRP/A)
Lisa Shea, RM/ALF, MS: MNBB 4503
MIS System
DRSS-FIPS
RIV File
Project Engineer (DRP/A)
R. Bachmann, 0GC, MS: 15-B-18
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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)
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Houston Lighting & Power
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File No.:
G02.04
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U.
S. Nuclear Regulatory Commission
Attention:
Document Control Desk
20555
South Texas Project
Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
Supplemental Response to Notice of Violation 9236-06
Recardina Failure to Request Relief from ASME Recuirements
!
Reference:
Correspondence from
S.
L.
Rosen, HL&P, to NRC,
dated April 2,
1993, " Reply to Notice of Violation
9236-06, Regarding Failure to Request Relief from-
ASME Requirements" (ST-HL-AE-4402)
Houston Lighting & Power Company (HL&P) provided'the initial
response to Notice of Violation 9236-06 via the reference noted-
above.
This supplemental response provides the results of the
analysis of the methodology required to meet the ASME Section XI
accuracy and the date of compliance with ASME Section XI for the
Essential Cooling Water (EW) system along with the date of full
compliance for this violation.
In the initial response to Notice of Violation 9236-06, HL&P
committed to revising procedures and calibration sheets in order to
allow the use of temporary flow measurement devices until the
existing instrumentation, fcr the Essential Chilled Water (CH) and
Safety Injection (SI) systems were precision calibrated to resolve
the inaccuracies.
Contrary to this commitment, the High Head
Safety Injection (HHSI) Pump 1A Inservice Test and the Essential
Chilled
Water
Pump
11C
Inservice
Test
were
performed
on
t
April 5,
1993, and April 15, 1993, respectively, using an unrevised
procedure and existing flow instrumentation.
,
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1R\\93-125.002
Project Manager on Behalf of the Participants in the South Texas Project
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Houston, Lighting & Power Company
South Texas Project Electric Generating Station
ST-HL-AE-4436
File No.:
G02.04
Page 2
After HL&P committed to revising the procedures and the
controlotron calibration sheet prior to their next performance, the
Plant
Engineering Department
(PED)
reviewed the
surveillance
schedule and assumed that adequate time would be available prior to
,
the next performance of the surveillance to arrange for a vendor to
perform the precision calibrations on the existing flow measuring
devices. HL&P was unable to procure the services of a vendor prior
to April
15,
1993.
Changes to the existing procedures were
initiated on April 14, 1993, but were not completed prior to the
performance of the Essential Chilled Water pump inservice test
scheduled
for
April
15,
1993.
The
Unit
1
Pump
1A
surveillance, performed on April
5,
1993, had been placed on
increased frequency and was not accounted for in the initial review
of the surveillance schedule.
The actions taken to address this
failure to meet a commitment are provided in Section V.
,
All changes to the initial response for this Notice of
Violation are denoted by revision bars.
If you have any questions, please contact Mr.
C.
A.
Ayala at
(512) 972-8628 or me at (512) 972-7138.
,
,
Rosen
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Vice President,
Nuclear Engineering
GLM/nl
Attachment:
Supplemental Response to Notice of Violation 9236-06.
IR\\93-125.002
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. Houston. Lighting & Power Company
. South Texas Project Electric Generating Station
Pf-HL-AE-443G:
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File No.:
G02.04
Page 3
c:
Regional Administrator, Region IV
Rufus S.
Scott
Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 400
Hcuston
Lighting
&
Power
Company
Arlington, TX
76011
P.
O.
Box 61867
Houston, TX
77208
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Project Manager
U.S. Nuclear Regulatory Commission
Institute of Nuclear Power
20555
Operations - Records Center
'
1100 Circle 75 Parkway
J.
I. Tapia
Atlanta, GA
30339-3064
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
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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
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1
20036
Austin, TX
.78756-31G9
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
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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
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City Public Service
P.
O.
Box 1771
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San Antonio, TX
78296
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IR\\93-125.002
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Attachment 1
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ST-HL-AE-4436
Page 1 of 3
I.
Statement of Violation:
Failure to Reauest Relief from ASME Code Reauirements
10 CFR 50.55a requires that ASME Code Class 3 pumps and valves
)
whose function is required for safety undergo IST which complies
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with the requirements of ASME Section XI to verify operational
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readiness, unless relief has been granted.
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Article IWP-4110 of ASME Section XI, requires that instruments
.
used in IST be of a quality such that instrument accuracy is
,
within 2 percent of full scale.
'
Contrary to the above, the essential cooling water flow element
installation for the Units 1 and 2 component cooling water heat
-
exchanger had an error of 7 percent of full scale and no relief
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from the provisions of Section XI was granted.
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This
is
a
Severity Level
IV violation.
(Supplement
I)
(498;499/9236-06)
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II.
Houston Lichtina & Power Position:
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HL&P concurs that the cited violation occurred.
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III.
Reason for Violatic,:
[
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The cause of the event was inadequate management controls to
ensure that request for relief from'the requirements of ASME
'
Section XI was submitted in a timely manner.
IV.
Corrective Actions:
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1.
An investigation was performed to determine-if instrument
inaccuracies similar to those discovered in the Essential
Cooling Water (EW) System existed in other systems.
Similar
instrument inaccuracies were discovered in the Essential
Chilled Water (CH) and Safety Injection (SI) systems.
2.
An evaluation of the data collected during previous ASME
,
Section XI pump testing was conducted and concluded that the
EW, CH, and SI instrumentation provided results capable of
detecting pump degradation and therefore met the intent of
System operability for EW, CH,'and SI was.
reviewed and was determined to not be a concern due to
sufficient margin existing
between the design and the
required system flow rates.
IR\\93-125,002
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Attachment 1
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ST-HL-AE-4436
Page 2 of 3
IV.
Corrective Actions:
(con't)
3.
temporary flow measurement
devices capable of achieving the required ASME Section XI
accuracy will be used until the existing instrumentation is
precision calibrated to resolve the inaccuracies.
Use of
these devices requires revision to the reference value
procedures,
inservice test procedures,
and controlotron
calibration specification sheets for the CH and SI systems.
These revisions will be completed prior to their next
performance.
4.
For the EW system, the existing instrumentation will be
precision calibrated to resolve the inaccuracies.
This
precision calibration is tentatively scheduled to begin by
the end of May and will be completed prior to June 30, 1993.
HL&P will be in compliance with the requirements of ASME
Section XI upon completion of the precision calibration.
5.
Procedures OPGP03-ZE-0021, " Inservice Testing Program for
Valves", and OPGP03-ZE-0022, " Inservice Testing Program for
Pumps"
will be revised to require that relief requests be
submitted to the NRC within six months of discovery of the
need for the requests.
This revision will also require that
compensatory actions be taken, as required, until the relief
request is granted by the NRC.
These procedures will be
revised by September 23, 1993.
6.
To
prevent
recurrence,
procedure
IP-3.04Q,
" Inservice
Inspection
Program",
was
revised
to
require
that
the
responsible engineer ensure that the instrumentation used to
collect data for inservice testing is accurate to within the
tolerances specified in ASME Section XI prior to inclusion
of the instrumentation in the testing plan.
In addition,
procedure OPGP03-ZE-0031, " Design Change Implementation",
was revised to require consideration of programmatic impact
to the ASME Section XI Pump and Valve Testing Program in the
event of a design change to the existing configuration.
Also,
the
+/-
2%
instrument accuracy was specifically
identified as a potential impact to Section XI equipment on
the Design Change checklist.
1R\\93-125.002
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Attachment 1
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ST-HL-AE-4436
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Page 3 of 3
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V.
Actions Taken to Address Failure to Meet Commitment:
Upon discovery of the surveillance performance with an unrevised
l
procedure, a Station Problem Report was issued and revision of
the
applicable
procedures
and
calibration
specification sheet was subsequently completed.
A training
i
bulletin will be distributed to the appropriate STP-personnel
concerning this event,
emphasizing. the. . need for increased
attention
to
detail
with
regards
to
corrective. actions
associated with NRC commitments. The personnel involved in this
.
,
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failure to meet an NRC commitment will be counseled on the
importance of attention to detail with regards to corrective
actions associated with NRC commitments.
These actions will be
completed by June 1,
1993.
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VI.
Date of Full Compliance:
The
and
systems
will
be
in
compliance
with
the
i
requirements of ASME Section XI prior to the next performance of
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HL&P will be in full compliance prior to June 30, 1993.
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