ML20195G839

Notice of Violation from Insp on 880425-29.Violation Noted: Documentation File for Valve Operator Assembly Model Pf 89270-500 Did Not Adequately Support Qualification

ML20195G839
Person / Time
Site:	South Texas
Issue date:	06/20/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195G813	List: IR 05000498/1988030 ML20195G808 ML20195G839
References
50-498-88-30, NUDOCS 8806280161
Download: ML20195G839 (2)

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APPENDIX A

. NOTICE OF VIOLATION Houston Lighting & Power Company- Docket: 50-498' South Texas Project,; Unit 1- Operating License: NPF-76 During an NRC inspection conducted on April 25-29, 1988, a violation of NRC requirements was identified.. The violation involved HL&P's failure to have an adequate basis, when using Buna-N materials in place of Viton and ethylene propylene rubber (EPR), to establish qualification of the four steam generator (SG) power _ operated relief valves (PORVs), supplied by Control Component.Inc., and manufactured by Paul-Munroe Enertech. In accordance with-the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1988), the violation is listed below:

Paragraph (f) of 10 CFR 50.49 requires that qualification of each component must be based on testing or experience with identical equipment or with similar equipment with-a supporting analysis to show that the equipment to be qualified-is acceptable.

Paragraph (k) of 10 CFR 50.49' requires that' equipment previously required by the' Commission to be qualified to NUREG-0588 (For Comment version),

"Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," need not be requalified.

Paragraph 5(1) of NUREG-0588 requires that the qualification documentation shall verify that each type of electrical equipment is qualified for its application and meets its specified performance requirements. The basis of qualification shall be explained to show the relationship of all-facets of proof needed to support adequacy of the complete equipment. Data used to demonstrate the qualification of the equipment shall be pertinent to the application and organized in an auditable form.

Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Section 5(1) of NUREG-0588, Category I, the HL&P/Bechtel equipment qualification (EQ) documentation file for valve operator assembly Model No. PF 89270-500 (PORV which includes the hydraulic cylinder and hydraulic pump), did not adequately-support qualification in that similarity between the type test configuration and that installed in the STP plant, Unit 1, could not be established. Specifically, no analysis was_available to demonstrate that Buna-N (nitrile rubber) seai materials are acceptable for an accident environment which may exist at the PORV.

This is a Severity Level IV violation. (Supplement I)(498/8830-01) 4 Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Powe' Company is hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, G

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(3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas, this Jo t/v day of % 1988.

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