ML20154E943

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/88-38 & 50-499/88-38

ML20154E943
Person / Time
Site:	South Texas
Issue date:	09/12/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8809190197
Download: ML20154E943 (2)

See also: IR 05000498/1988038

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SEP l 2 !988

In Reply Refer To:

Dockets: 50-498/88-38

50-499/88-38

Houston Lighting & Power Company

ATTN: J. H. Goldberg, Group Vice

President, Nuclear

P.O. Sox 1700

Houston, Texas 77001

Gentlemen:

Thank you for your letter of August 19, 1988, in response to our letter

and Notice of Violation dated July 20, 1988. 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 detemine that (W1 compliance has been achieved and will be maintained.

Sincerely.

Oririn't fir v d i-

L j r m.o

L. J. Callan Director

Division of Reactor Projects

cc:

Houston Lighting & Power Company Newman & Holtzinger, P.C.

ATTN: M. A. McBurnett, Manager ATTN: J. R. Newman, Esquire

Operations Support Licensing 1615 L Street, N.W.

P.O. Box 289 Washington, D.C. 20036

Wadsworth. Texas 77483

Houston Lighting & Power Company Houston Lighting & Power Company

ATTN: Gerald E. Vaughn, Vice President ATTN: S. L. Rosen

Nuclear Operations P.O. Box 289

P.O. Box 289 Wadsworth, Texas 77483

Wadsworth. Texas 77483

Houston Lighting & Power Company Houston Lighting & Power Cornpany

ATin: J. T. Westermeier, General Manager ATTN: R. W. Chewning Chairman

South Texas Project Nuclear Safety Review Board

P.O. Box 289 P.O. Box 289

Wadsworth, Texas 77483 Wadsworth, Texas 77483

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Houston Lighting & Power Company -2-

Central Power & Light Company City Public Service Board

ATTN: R. L. Range /R. P. Verret ATTN: R. J. Costello/M. T. Hardt

P.O. Box 2121 P.O. Box 1771

Corpus Christi, Texas 78403 San Antonio, Texas 78296

City of Austin Electric Utility Houston Lighting & Power Company

ATTN: R. J. Miner, Chief Operating ATTN: Licensing Representative

Officer Suite 610

721 Barton Springs Road Three Metro Center

Austin, Texas 78704 Bethesda, Maryland 20814

Texas Radiation Control Program Director

bec to DMB (IE01)

bec distrib, by RIV:

DRP RRI-OPS

R. D. Martin, RA DRS

Section Chief (DRP/D) RPB-DRSS

MIS System RIV File

Lisa Shea, RM/ALF RSTS Operator

R. Bachmann 0GC D. Hunnicutt

G. Dick, NRR P.'oject Manager Project Engineer, DRP/D

RRI-CONST L. Gilbert

1. Barnes

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August 19, 1988

ST-HL-AE- 2755

File No.: G2.4

10CFR2.201

U. S. Nuclear Regulatory Comission

Attention: Docu:nent Control Desk

Washington, DC 20555

South Texas Project Electric Generating Station

Units 1 and 2

Docket Nos. STN 50-498, STN 50 499

L.00nse to Notien of Violation 498/4(9 8R-38-01

Houston Lighting & Power Company has reviewed Notice of Violation 498/499

88-38-01 dated July 8, 1988, and submits the attached response pursuant to

10CTR2.201.

If you should have any questions on this matter, please contact Mr.

M. F. Po11shak at (512) 972-7071.

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J. H. Goldberg

Group Vice President, Nuclear '

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Attachment: Response to Notice of Violation

498/499 881J 01

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Regional Adininistrator, Region IV Rufus S. Scott

Nuclear Regulatory Comrnission Associate General Counsel

611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company

Arlington, TX 76011 P. O. Box 1700

Houston, TX 77001

Coorge Dick, Project Manager

U.S. Nuclear Regulatory Coraission INPO

Vashington, DC 20555 Records Center

1100 Circle 75 Parkvay

Jack E. 3ess Atltnta, CA '3339 3064

Resident Inspector / Operations

e/o U.S. Nuclear Regulatory Dr. Joseph M. Hendrie

Coeaission 50 Be11 port Lane

P. O. Box 910 Be11 port, b'Y 11713

Bay City, TX 77414

Don L. Carrison

Resident Inspector / Construction

c/o U.S. Nuclear Regulatory -

Cocaission

P. O. Box 910

Bay city TX 77414

J. R. Ne m an, Esquire

Newan & Holtzinger, P.C.

1615 L S t r e e t , N. V.

Vashington, DC 20036

R. L. Range /R. P. Verret

Central Power & Light Company

P. O. Box 2121

Corpus Chrit:1, TX 78403

R. John Miner (2 copies)

Chief Operating Officer

City of Austin Electric Utility ,

721 Barton Springs Road

Austin, TX 78704

R. J. Costello/M. T. Hardt

City Public Service Board

P. O. Box 1771

San Antonio, TX 78296

Revise d 06/15/88

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Attechment

. M @"8 ' %8 Cornpany ST-HL-AE-2755

. File No.: G2.4

Page 1 of 4

Response to Notice of Violation 498/499 88-33 F

I. Statement of Violation

During an NRC inspection conducted on June 27 through July 1- J the

following violation of NRC requiroments was identified for f 4ure to

follow instructions for measuring remaining pipe wall thickness.

Criterion V of Appendix U to 10 CFP. Part 50 requires that activities

affecting quality shall be proscribed by documented instructions of a

type appropriate to the circumstancer and shall be accomplished in

accordance with these instructions. This requirement is amplified by the

approved Quality Assurance Program Description (QAPD) of the South Texas

Project.

A nonconformance report, NCR SS-05553, required the reaeval of a magnetic

particle examination indication from pipe spool AF-2012-H. The .

instructions of the nonconfornance report were to excavate the indication

but not go below a remaining wall thickness of 0.437 inch.

Contrary to the above, NCR 3S-05553 was Jmproperly closed in that

ultrasonic thickness measurements, made after quality control (QC)

closeout of the NCR, showed that the actual remaining wall thickness in

the excavation area was 0.418 inch. Initial QC acceptance was determined

subsequently to have been the result of use of an incorrect inspection

method (i.e., estimating remaini.g wall thickness by subtracting depth of

excavation from pipe nominal wall thickness).

II. Reason for Violaj_iy l

The implementing procedures utilized for Quality Control verification of

existing pipe wall thickness were misinterpreted by Quality Control

inspection personnel, ai.d the pipe wall thickness was detarmined by

subtracting the depth of excavation from the nominal pipe wall thickness.

III. Corrsetive Action Taken and Results Achieved

As committed by HL&P in the July 1, 1988 NRC Exit interview, a review of

Customer Notification Forms (CNFs), initiated by Southwest Research

Institute, the project Preservice Inspection (PSI) contractor, has been

completed to identify if any additional minimum pipe wall violations have

resulted due to QC inspectors using nominal wall thickness tables and

depth of excavation for determining remaining wall thickness.

CNF(s) shich identified surface and heat affected zone indications were

reviewc,2. Counterbored piping prepared for Pre-Service and In-Service

weld inspectica and receiving subsequent surface metal reduction

represented the areas of cone" n or worst case scenarios. Two hundred

Snd four (204) Unit 1 and Unit 2 CNF's were identified as applicable.

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ST-ML-AE-2755

File No.: G2.4

. Page 2 of 4

A thorough review of CNF's and associated documentation was performed

to identify instances where grinding took place. Those records thus

identified as involving measurement of pipe wall thickness were then

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reviewed to determine the method utilized.

The Unit 1 CNF review did not identify any wall thickness violations due

to indication removal. Additionally, no condition was identified where

remaining wall thickness had been determined by subtracting the depth of

excavation from pipe nominal wall thickness.

The Unit 2 review revealed one (1) similar condition whereby remaining

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wall thickness was determir.ed by subtracting the depth of excavation from

pipe nominal wall thickness. Subssquent Ultrasonic Testing (UT) verified

this pipe wall thickness to be acceptabla.

The review of Unit 1 and Unit 2 Pre-Service Inspection CNFs has been

completed. No case, other than NCR SS-05553, was identified where

minimum wall violations have occurred due to Pre-Service Inspection

Non-Destructive Examination indication removal.

IV. Corrective Steps Taken to Prevent Recurrence

STP plant maintenance procedures provide adequate inspection guidelines

to prevent misinterpectation of pipe wall measurement method. They do

not permit the estimatinE of remaining wall thickness by subtracting the

depth of excavation from the pipe's nominal wall thickness value.

Ultrasonic Testing or measurement of remaining pipe wall thickness using

calibrated equipment is required.

Construction Site Standard Procedure (SSP-18) "General ASME III Welding

Requirements" and Site Standard Procedure (SSP-17), "General ANSI B31.1

Welding Requirements", which provide inspection guidelines for

determining pipe wall thickness utilizing mechanical means have been

revised. A standard measuring device such as a caliper or micrometer is

required to mnasure actual remaining wall thickness where accessible.

Where inaccessible for utilizing a standard measuring device, direct

ultrasonic testing may be used. When direct ultrasonic testing of an

area is not possible. UT is to be performed along the periphery of

eacavated areas and the thickness of the thinnest section determined.

The depth of excavation is measured utilizing an inspection instrument

capable of reaching the bottom of the excavated area. This value is

subtracted from the lowest UT reading achieved to dete rmine remaining

pipe wall thickness,

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Houston L4)hting & Pow Company

ST-HL-AE-2755

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File No.: G2.4

Page 3 of 4

QC inspectors associated with piping installations have been instructed

in use of the revised SSP-18 procedure.

Field engineering personnel associated with piping installation have been

instructed in use of the revised SSP-17 procedure.

V. Additional Investinative Steps Taken and Results Achieved

In addition to the aforementioned review of CNF's the project performed a

review of Unit 2 programmatic documents utilized at STP to report

discrepant piping surface conditions, to gain additional confidence that

the NCR SS-05553 infringement of design minimum vall is an isolated

occurrence. These documents are identified as ivilows.

1) Base Material Surface Condition Reports (BMSCR)

2) Deficiency Notices (DN)

3) Nonconformance Reports (NCR) .

Unit 2 documentation was treated as representative of conditions for the

entire project.

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The review of these documents concentrated on repairs performed by

grinding which did not require subsequent welding activities on Quality

Class 1, 2 and 3 piping lines to identify if wall thickness was

determined by subtracting the depth of excavation from the nominal wall

thickness. This review was completed and revealed five additional cases

of acceptance of items by Quality Control based on the depth of

excavation =ubtracted from nominal wall thickness measurement method.

Four (4) areas were identified cr. Deficiency Notices, and the other on a

Base Material Surface Condition Report. All five cases have been

ultrasonically examined and 'ound to be well above design minimum wall

thickness. The remaining documents reviewed were found to be acceptable

based on the measurement method performed (i.e., direct ultrasonic

testing, or calibrated micrometer measurement), rface blend, or the

affected area was repeired by welding.

The project next reviewed ASME piping systems for minimum pipe wall

requirements. Portions of piping systems were identified where the

excess wall between manufacturers minimum wall and calculated design

minimum wall is 1/32" or less. These lines (the most limiting cases)

were reviewed against the population of BHSCR's, DN's and NCR's

previously discussed. No cases were found where the depth of excavation

was subtracted from nominal wall thickness to obtain remaining pipe wall.

Unit 2 Qsality Class 1 and 2 (vendor and field counterbored piping) and i

Quality Class 3 (field counterbored) piping lines were reviewed to

determine locations where countorboring had been performed. This review

included determining if repairs by grinding had been performed in the

counterbored area to identify if remaining wall thickness was determined

by subtracting the depth of excavation from the nominal wall thickness.

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This review consisted of over 5,500 vaulted weld data packages and 2,900

pipe spool data packages. Thirteen (13) areas vera identified where

basemetal surface condition repairs within the heat affected zone (HAZ)

on the Pipe Pressure Boundary were accepted by Quality Control and the

mechanical measurement method used (i.e, caliper, micrometer or depth of

excavation) was not clearly document ed. Af ter further evaluation six (6)

areas required wall thickness verification. Ultrasonic testing has been

performed on two of these areas and the wall thickness verified

acceptable. The remaining four (4) areas are inaccessible at this time

and are scheduled to be verified by September 30, 1988. This response

will be supplemented by October 14, 1988 with the results of the

remaining wall thickness measurements.

The investigation to date of Unit 2 Class 1, 2 and 3 counterbored welds,

the review of Bechtel identified piping lines hsving the least excess

wall thickness, and the review of BMSCR's, DN's, and NCR'a for ASME

piping, yields a high confidence level for the Project (Unit 1 and 2)

that infringement of design minimum wall per NCR SS-05553 thus far is an

isolated occurrence and no additional reviews are necessary beyond the

ren.atning four verifications discussed in the previous paragraph.

VI. Date of Full Comoliance

HL&P is in full compliance.

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