ML20197F306
| 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: |
| 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
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REGloN IV
611 RY AN PL AZA DRIVE, SUITE 400
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AH i,1?dG TON, N X AS 760118064
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void a superseded uncertainty calculation affecting a surveillance procedure; 3) assure that the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.
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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
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facihty. While the NRC remains concerned about these indicators, we do not Lelieve that the
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violatiota constitute a breakdown in your design control program. Therefore, the violctions have
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
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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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
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.
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
Records Center
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._700 Galleria Parkway
Atlaata, Georgia 30339-5957
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Bureau of Radiation Control
State of Texas
11,00 West 49th Street
Mr. Glenn W. Dishong
Texas Public Utility Commission
7800 Shoal Creek Blvd.
Suite 400N
John Howard, Director
Environmental and Natural Resources Policy
Office of the Governor .
P.O. Box 12428
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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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