ML20154E943
| 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
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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-
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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
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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
Bethesda, Maryland 20814
Texas Radiation Control Program Director
bec to DMB (IE01)
bec distrib, by RIV:
RRI-OPS
R. D. Martin, RA
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
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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ec:
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
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
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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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ST-HL-AE-2755
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File No.: G2.4
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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-
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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
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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
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File No.: G2.4
Page 2 of 4
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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
reviewed to determine the method utilized.
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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
wall thickness was determir.ed by subtracting the depth of excavation from
pipe nominal wall thickness.
Subssquent Ultrasonic Testing (UT) verified
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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)
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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
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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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ST-HL-AE-2755
File No.: G2.4
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Page 4 of 4
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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