ML20197F306

Discusses Insp Repts 50-498/97-24 & 50-499/97-24 & Forwards Notice of Violation

ML20197F306
Person / Time
Site:	South Texas
Issue date:	12/22/1997
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
Shared Package
ML20197F312	List: ML20197F306 ML20197F346
References
50-498-97-24, 50-499-97-24, EA-97-523, NUDOCS 9712300181
Download: ML20197F306 (5)

See also: IR 05000498/1997024

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, NUCLEAR REGULATORY COf.iMISSION

h )d e REGloN IV

611 RY AN PL AZA DRIVE, SUITE 400

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• • • • • Daceaner 22, 1997

EA 97 523

William T. Cottle, President

South Texas Project Nuclear Operating Company

P.O. Box 289

Wadsworth, Texas 77483

SUBJECT: NOTICE OF VlOL ATION

(NRC INSPECTION REPORT 50-498/97-24; 50-499/97-24)

Dear Mr. Cottle:

This is in reference to the predecisional enforcement conference conducted in the NRC's

Arlington, Texas office on December 8,1997. The conference was conducted to discuss

apparent violations of NRC requirements at the South Texas Project Electric Genecating

Station (STP). The apparent violations were described in the referenced NRC inspection report,

issued November 21,1997. The inspection, which was completed November 12,1997, foct. sed

on the STP design control program and the adequacy of design-related calculations.

Based on the information developed during the inspection, and consideration of the information

that you provided during the conference, the NRC has determined that violations of NRC

requirements occurred. The violations are cited in the enclosed Notice of Violation, and the

circumstances surrounding them were described in & tail in the subject inspection report.

The violations include failures to: 1) take prompt action to correct known setpoint deficiencies; 2)

void a superseded uncertainty calculation affecting a surveillance procedure; 3) assure that the

appropriate uncertainty assumptions were factored into proedures requiring the use of

measuring and test equipment; 4) amend auxiliary power load study calculations in accordance

with procedures; and 5) update the safety analysis report to reflect revised refueling water

storage tank level calculations.

/

The NRC believes that these violations indicate weaknesses in your program for controlling and[ '

assuring the adequacy of design related calculations and setpoints. Although these violations ,

do not appear to have affected design assumptions to such an extent that safety-related

equipment would no longer be considereo operable, these failures had the potential to affect

such assumptions. The NRC views your failure to promptly correct known deficiencies in

setpoint calculations that you have been aware of since 1992 as a serious lapse in determining

priorities, especially given the importance of design-related setpoints to the overall )safety of

facihty. While the NRC remains concerned about these indicators, we do not Lelieve that the

violatiota constitute a breakdown in your design control program. Therefore, the violctions have

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been classified individually at Severity Level IV in accordance with the " General Statement of

Pohey and Procedure for NRC Enforcement Actions,' NURE ;-1600, as revised.

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9712300181 971222

PDR ADOCK 05000498

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Please note that the violations being cited differ from the apparent violations specified in the

inspection report in the following respects: 1) the violation (50-498;-499/9724-07) involving a

. failure to assure that a calculated instrument uncertainty was translated to a plant operating

procedure is being treated as a non-cited violation consistent with Section Vll.B.1 of the NRC's

Enfucement Policy because it was licensee-identiied and corrected and was non-repetitive;

2) the apparent violations of 10 CFR Part 50, Appendix B, Criterion lli (Design Control), involving

a superseded uncertainty calculation and the accuracy of measuring and test equipment, have

been converted to viciations of Appendix B, Cnterion V (Instructions, Procedures and Drawings);

and 3) the apparent violation of 10 CFR 50.59 involving validation of RWST level setpoints, has

been converted to a violation of 10 CFR 50.71(e) for a failure to update the facility Final Safety

Analysis Report.

In addition, the apparent violation (50-498;-499/9724-03) of Appendix B, Criterion 111, involving

the failure to update certain auxiliary feedwater and emergency diesel generator loading

calculations to reflect design changes to the facility, is not being cited. While the NRC views the

failure to update or eliminate certain calculations as a weakness in your practices that has the

potential to result in violations involving design control, the NRC generally agrees with the

position that you postulated at the conference that impact reviews were done, albeit informally,

and therefore that these dise,apancies did not result in a loss of design control for the systems

and components involvad in the examples, and did not result in violations of NRC requirements.

You are required to respond to this letter ar.d should follow the instructions specified in the

enclosed Notice when preparing your response. In your response, you should document the

specific actions taken and any additional actions you plan to prevent recurrence. The NRC will

use your response, in part, to determine whether further enforcement action is necessary to

ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely,

t/

Ellis W. Mersch

Regional Ad istrator

,

Docket Nos. 50-498; 50-499

License Nos. NPF-76; NPF 80

Enclosure: Notice of Violation

cc w/Enclos"re: (see next page)

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I Lawrence E. Martin, Vice President

Nuclear Assurance & Licensing

STP Nuclear Operating Company

P.O. Box 289

Wadsworth Texas 77483

Mr. J. C. Lanicr/Mr. A. Ramirez

City of Austin

Electric Utili'y Department

721 Bartor. 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

C. R. Crisp /R. L. Balcom

Houston Lighting & Power Company

P.O. Box 1700

Houston, Texas 77251

Jon C. Wood

Matthews & Branscomb

One Alamo Center

106 S. St. Mary's Street, Suite 700

San Antonio, Texas 78205 3692

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

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._700 Galleria Parkway

Atlaata, Georgia 30339-5957

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__________________________,

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Bureau of Radiation Control

State of Texas

11,00 West 49th Street

Austin, Texas 78756

Mr. Glenn W. Dishong

Texas Public Utility Commission

7800 Shoal Creek Blvd.

Suite 400N

Austin, Texas 78757-1024

John Howard, Director

Environmental and Natural Resources 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

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