IR 05000498/1996006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/96-06 & 50-499/96-06

ML20138N197
Person / Time
Site:	South Texas
Issue date:	02/24/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
NUDOCS 9702270181
Download: ML20138N197 (5)

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[., , ' *. NUCLEAR REGULATORY COMMISSION h .) RE GloN IV

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i William T. Cottle, Group Vice ,

President, Nuclear l Houston Lighting & Power Company P O. Box 289 Wadsworth, Texas 77483 SUBJECT: NRC INSPECTION REPORT 50-498/96-06: 50-499/96-06 ,

Dear Mr. Cottle:

Thank you for your letter of December 16,1996,in response to inspection ,

Report 50-498/96-06:50-499/96-06. We have reviewed your clarifications regarding

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issues associated with the Spent Fuel Pools and an associated Unresolved item (96-006-04). We find your letter helpful in addressing the concerns raised in our j inspection report. We will further review the clarifications during a future inspection when

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we followup on the unresolved item.  !

Sincerely, l

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Arthur T. Howe Ill, Acting Director Division of Reactor Projects i

Dscket Nos.: 50-498  !

50-499 j License Nos.: NPF-76 j NPF-80 )

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Lawrence E. Martin, General Manager Nuclear Assurance & Licensing Houston Lighting & Power Company P.O. Box 289 l Wadsworth, Texas 77483 gl )

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9702270181 970224 PDR ADOCK 05000498 G PDR T10016 555EPPPN.E.l! l J

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Houston Lighting & Power Company -2-Mr. J. C. Lanier/Mr. M. B. Lee City of Austin Electric Utility Department 721 Barton Springs Road Austin, Texas 78704 Mr. K. J. Fiedler/Mr. M. T. Hardt City Public Service Board P.O. Box 1771 San Antonio, Texas 78296 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 Dr. Bertram Wolfe 15453 Via Vaquero Monte Sereno, California 95030 1

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Bureau of Radiation Control j State of Texas ,

1100 West 49th Street  !

Austin, Texts 78756 l l

l Mr. Glenn W. Dishong l Texas Public Utility Commission  !

7800 Shoal Creek Blvd. '

l Suite 400N i Austin, Texas 78757-1024 l

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Houston Lighting & Power Company -3-Andy Barrett, Director Environmental Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 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 Rufus S. Scott, Associate General Counsel Houston Lighting & Power Company P.O. Box 61867 Houston, Texas 77208 Joseph R. Egan, Esq.

Egan & Associates, P.C.

2300 N Street, N.W.

Washington, D.C. 20037 Mr. J. W. Beck Little Harbor Consultants, Inc 44 Nichols Road Cohasset, MA 02025-1166

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i Houston Lighting & Power Company -4- FEB 2 41997 i

bcc to DMB (IE01)

bec distrib. by RIV:

L. J. Callan Resident inspector f DRP Director DRS-PSB 1 Branch Chief (DRP/A) MIS System Project Engineer (DRP/A)- RIV File Branch Chief (DRP/TSS) R. Bachmann, OGC (MS: 15-B-18)  ;

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)  ;

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l DOCUMENT NAME: R:\_STP\ST606AK.DPL To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy PE:DRP/A C:DRP/A , D:DRPg RAKopriva;cmA( JITapia Wf/ JED W h 2//J/97 2/ 6/97 l; 2/f387U OFFICIAL RECORD COPY

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Houston Lighting & Power Company -4- FEB 2 41997 i

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bec distrib. by RIV:  ;

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L. J. Callan Resident inspector  ;

4 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) l

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Leah Tremper (OC/LFDCB, MS: TWFN 9E10) .

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I DOCUMENT NAME: R:\_STP\ST606AK.DPL To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy PE:DRP/A . C:DRP/A y D:DRPg RAKopriva;cmg JITapia W/ JED W p 2//J/97 2/ 3/97 [j 2/q'38M OFFICIAL RECORD COPY

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l The compng&Likht Houston Ligh Poweray South Texas Project 1:lectric Generating Station P.O. Itox 289 Wadsworth. Texas 77483 l

16 1996 '

Decembe ST-HL-AE-r '5489 ,

File No.: G03.12 J. E. Dyer, Director DEC I e':- '-

Division of Reactor Projects '

U. S. Nuclear Regulatory Conunission, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 l

South Texas Project Units 1 and 2 1 Docket Nos. STN 50-498, STN 50-499 Response to NRC Inspection Report 50 4 98/96-06: 50-499/96-06

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Reference: Ixtter from J. E. Dyer, NRC to W. T. Cottle, South Texas Project, dated l October 2,1996 (ST-AE-HL-94659)

, This letter was developed in response to NRC Inspection Report 50-498/96-06; 50-499/96-06

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to resolve apparent misunderstandings regarding issues associated with the Spent Fuel Pools

(Attachment 1). This letter will also answer the concerns and questions pertaining to the

" implications of having nonsafety-related gate seals" as characterized in Unresolved Item 96-006-04 (Attachment 2).

As you are aware, there have been many in-depth inspection activities directed at design issues associated with the South Texas Project's Spent Fuel Pools. In addition, South Texas Project has thoroughly reviewed the design and licensing bases associated with the Spent Fuel Pools. Based on these myiews, we are convinced that there are no safety issues associated with the design or operation of the Spent Fuel Pools at South Texas Project. Notwithstanding this, we have recently completed fabrication and installation of permanent stainless steel walls in the cask connecting channel for both units If you have any questions regarding this, please contact me at (512) 972-8787, or Mr. E. D.

Halpin at (512) 972-7849.

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T. H. Cloni er i Vice Pres' e ,

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mecring KDH/esh Attachments: 1) Response to Inspection Report 96-06 2) Response to Unresolved Item 96-006-04 77-04IB Psoject Manager on 11ehalf of the Participants in G, South Texas Project-h- J

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i Houston Lighting & Power Company l

South Texas Project Electric Generating Station ST-HL-AE-5489 :

File No.: G03.12 i Page 2  ;

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Leonard J. Callan Rufus S. Scott ,

Regional Administrator, Region IV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company (

611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 i Arlington, TX 76011-8064 Houston, TX 77208 i

Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H3 Operations - Records Center

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U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957

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David P. Loveless Dr. Bertram Wolfe Sr. Resident Inspector 15453 Via Vaquero  :

c/o U. S. Nuclear Regulatory Comm.

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Monte Sereno, CA 95030 i P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff i Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health i Morgan, Lewis & Bockius 1100 West 49th Street

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1800 M Street, N.W. Austin, TX 78756-3189

. Washington, DC 2.0036-5869 J. R. Egan, Esquire M. T. Hardt/W. C. Gunst Egan & Associates, P.C.

City Public Service 2300 N Street, N.W.

P. O. Box 1771 Washington, D.C. 20037

, San Antonio, TX 78296 J. C. Lanier/M. B. Lee U. S. Nuclear Regulatory Commission ;

City of Austin Attention: Document Control Desk Electric Utility Department Washington, D.C. 20555-0001 721 Barton Springs Road Austin, TX 78704 i

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Central Power and Light Company J. W. Beck ATfN: G. E. Vaughn/C. A. Johnson Linto Harbor Consultants, Inc.

P. O. Box 289, Mail Code: N5012 4s Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166

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Attachment 1 l ST-HI-AE-5489 l Page 1 ;

ATTACilMENT 1 RESPONSE TO INSPECTION REPORT 96-06

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On Page 15, Section E8.1.b, Observations and Findings, the following statement appears:

"Engincers stated that a decision had been made not to perform Procedure OPOP07-FH-0001 [ sic] because of concerns that the test would cause the inner seal to begin leaking."

So th Texas Project developed preventative maintenance procedures for SFP seal replacerrent in 1995. In support of these activities, the station also developed procedure OPEP07-FH-0001, " Spent Fuel Pool Gate Seal Operability Check" to serify seal operaMlity. A properly inflated seal is the primary consideration for preventing SFP inventory loss. Therefore, this procedure specifically is designed to ensure that the new seal is capable of maintaining air pressure when inflated and subjected to the hydrostatic force applied by SFP water. Once validated, this capability can only be diminished by seal damage or degradation. ._

SFP gates are removed and installed in accordance with plant maintenance procedure OPMPO4-FH-0005, "In-Containment Storage Area and Spent Fuel Pool Gate Removal and Reinstallation". This procedure requires visual inspections of all sealing surfaces and specific inspection of the seal for tears, blisters, extreme wear, etc. The intent of these inspections is to inspect the gate and seal for any damage that may have occurred during removal or transit.

The work activities observed by NRC Resident Inspector (s) on August 8,1996 consisted of moving a gate from the transfer canal outer gate position in the SFP to the Cask Handling Area outer gate position. The gate was removed from the transfer canal area and installed in the cask handling area in accordance with OPMP04-FH-0005. The seal on this gate had been replaced and tested in accordance with OPEP07-FH-0001 in April, 1996. The seals were inspected during the relocation of the gate in accordance with OPMPO4-FH-0005. Based on the recent performance of OPEP07-FH-0001 and the scope of work performed, the control and inspection in OPMPO4-FH-0005 provided assurance of the operability of the seal.

Project Manager en Behalf of the Partidpants in the South Texas Project

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h. i Attachment 1 ST-HL-AE-5489 {

Page 2 On Page 15, Section E8.1.b, Observations and Findings. the following statement appears:

"It was determined that the licensee's 5-year plan scheduled the installation of a  !

spent fuel cask connecting channel gate for Unit 1 on July 31,1997, and on October 31,1997, for Unit 2. As of this inspection, no design work had been  :

conducted." l

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South Texas Project issued a design for a welded stainless steel wall to be installed in {

the Cask Handling Areas on October 10,1996. Actual design work commenced in i September,1995 when a design team comprised of engineering, operations, and station support personnel evaluated several design options. In accordance with station procedures, these evaluations consider the proposed designs' effectiveness, l constructability, and station impact (procedural, training, etc.). The design team, based l

on these evaluations, made a recommendation to station management to install a steel I wall in the Cask Handling Area. Although appamntly not evident, the design pmcess (pmliminary calculations, conceptual design development, cost / benefit analyses of feasible options, etc.) had definitely commenced by the time of the inspection. Station I management approved this plant modification in October,1995. The installation has recently been completed for both units. )

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On Page 16, Section E8.1.b, Observations and Findings. the following statements appear:

"The valves were not danger tagged closed nor in the locked valve program."

"An equipment clearance order had been written to danger tag the drain valves closed in July 1995. This was documented in NRC Inspection Report 95-20.

During a management meeting conducted in the Region IV office on July 25, 1995, senior licensee management had stated that, given the incomplete status of the cask handling areas, the associated drain valves would be closed and placed in the locked valve program. However, since that time, engineering personnel determined that the controls were not necessary and the danger tags were removed and the equipment clearance order was closed."

Following the July,1995 event, equipment clearance orders wem issued which closed and caution tagged all cask handling area drain valves in both units. As noted in our event investigation and NRC Inspection Report 95-21, the valves were originally not included in station valve Jineups. The drain valves were subsequently incorporated into valve lineups. Once the valves were procedurally positioned and controlled in l accordance with the valve lineup, the equipment clearance orders were removed. With regard to the July 25,1995 meeting, we believe that our intention was to convey that  !

the valves would be procedurally controlled by Plant Operations. Both the initial use i of caution tags and subsequent valve lineups meet this intent. '

Project Manager en Behalf of the Participants fra the South Texas Project

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Attachment 1 l ST-HL-AE-5489 - ;

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i On Page 16, Section E8.1.b, Observations and Findines. the following statement appears:

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" ... concerns with not having safety-related seals on the spent fuel pool gates remain."

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STP has determined that the gate seals are not required to maintain the reactor coolant I pressure boundary, assist in shutting down the reactor or maintaining it in a shutdown i condition, or to prevent / mitigate the consequences of an accident which could result in l

,offsite_ exposure comparable to the guidelines in 10CFR100. Therefore, we conclude j that the gate seals are properly classified as nonsafety-related. This classification is '

consistent with that of other nuclear sites we contacted. )

i South Texas Project also reviewed Regulatory Guide 1.13 " Spent Fuel Storage  !

Facility Design Basis". Position C6 of this guide states, in part, " mechanical systems  !

that by maloperation or failure could cause loss of coolant that would uncover fuel i should not be installed or included in the design. Systems for maintaining water  :

quantity should be designed so that any failure of such systems (including failures resulting from the Safe Shutdown Earthquake) will not cause fuel to be uncovered. .

These systems need not otherwise meet Category I seismic requirements." The bottom  ;

of the SFP gates are at elevation 39' 9" while the top of the acdve spent fuel is at j approximate elevation 38'. Since our design precludes fuel uncovery due to failure or l

maloperation of the SFP gates, the SFP gate seals are not required to be seismically l qualified.  !

Based on these reviews, South Texas Project has detemdned that the SFP gate seals I are properly classified as nonsafety-related and not subject to seismic Category I )

requirements. A similar evaluation was performed in 1984 by Bechtel Energy {

Corporation and South Texas Project.  !

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e Preiset Manager en Behat of the Participants in the South Tesas Project

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Attachment 2 '

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ST-HL-AE-5489 '

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ATTACHMENT 2 RESPONSE TO UNRESOLVED ITEM %-006-04

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" i 1) What design criteria was utilized for the seals during the original licensing l

review?

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, GDC 61 as reflected in Reg. Guide 1.13 " Spent Fuel Storage Facility Design Basis"  !

was used during the original licensing review. Specifically, Position C.6 which states  !

in part

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Mechanical systems that by maloperation or failure could cause loss of

! coolant that would uncover fuel should not be installed or included in 1

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the design. Systems for maintaining water quantity should be designed I i

so that any failure of such systems (including failures resulting from the j j Safe Shutdown Earthquake) will not cause fuel to be uncovered. These  ;

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systems need not otherwise meet Category I seismic requirements.

l For the STP design, this position is met with the use of non-safety related seals.  !

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I 2) What would be the final water level in the spent fuel pool should both nonsafety-

related seals fall? l

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, South Texas Project determined that the resultant water level in the spent fuel pool I

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following a postulated catastrophic failure of the SFP to Cask Handling Area gates l would be approximately 47'. This is approximately ten feet above the active fuel.

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This calculation assumed that all leak paths in the Cask Handling Area were isolated and fluid absorption by unlined concrete was negligible. This calculation was

presented to South Texas Project Resident Inspectors in July,1995 and Region IV

Inspectors in August,1995.

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L 3) Was the cask connecting channel gate considered a critical part of the originally

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accepted design' -

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As described in the original facility design, the cask connecting channel gate would ,

only be used in preparation for offsite transport of spent fuel. During these activities, j j this gate would be required to be installed and capable of maintaining water inventory I

in the SFP and Cask Handling Area.

Since no federal repository existed at the time of license review, South Texas Project  ;

l does not consider the cask connecting channel gate to be a critical part of our original  !

l or current SFP design.

l 1- Project Manager en Behalf of the T.# '. In the South Temas Project

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Attachment 2 ST-IIL-AE-5489 Page 2

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4) Has long-term exposure of the unfinished cask handling area surfaces to spent i fuel pool boric acid affected the integrity of the reinforcing steel?

Unfinished areas of the cask handling area have not been subjected to long-term exposure to boric acid. The cask connecting channel has experienced limited boric -

acid exposure during gate / seal maintenance or testing activities. These exposures have not resulted in damage to any exposed concrete due to the extremely limited exposure and evaporation timeframes. No deleterious effects of this exposure have been noted during engineering inspections of these areas.

5) Has the licensee performed a flooding analysis considering the potential for loss of the spent fuel pool gates?

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South Texas Project personnel have thoroughly inspected all portions of the cask handling area and found no equipment that would be affected following postulated l flooding from the SFP. The cask handling area is essentially a series of concrete vaults with no installed equipment required for plant operation. Based on these inspections, further flooding analysis is not warranted. i

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Project Manager on Behalf of the Partklpants in the South Texas Project