ML20199B175
| ML20199B175 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/22/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W AFFILIATION NOT ASSIGNED |
| References | |
| 50-498-97-24, 50-499-97-24, EA-97-523, NUDOCS 9801280195 | |
| Download: ML20199B175 (51) | |
See also: IR 05000498/1997024
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January 22, 1998
EA 97-523
William T. Cottle, President and
Chief Executive Officer
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, Texas 77483
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE SUMMARY
Dear Mr. Cottle:
This refers to the meeting with you and your staff conducted in the Region IV office on
December 8,1997. This Predecisional Enforcement Conference was convened to
discuss seven apparent violations: one related to corrective action, five related to design
control, and one related to 10 CFR 50.59 safety evaluations as discussed in NRC Inspection
Report 50-498/97 24; 50-499/97-24. The meeting was conducted in accordance with the
enclosed agenda. During the meeting, the NRC described the enforcement process and
discussed the daft apparent violations which are also attached. Your staff presented their
views regarding these issues. The handout which was provided as the basis for the discussion
is also enclosed,
in accordance with Section 2.790 of the NRC's nuies of Practice," Part 2, Title 10, Code of
Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them with
you.
Sincerely,
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Arthur T. How
lil, Director
Division of Reactor Safety
Docket Nos.: 504 98;50-499
9901290195 990122
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STP Nuclear Operating Company
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Enclosures:
1. Attendance List
2, Agenda-
3. Apparent Violations
4. Licensee Presentation
cc w/ enclosures:
Lawrence E. Martin, Vice President
Nuclear Assurance & Licensing
STP Nuclear operating Company
P.O. Box 20
Wadsworth, .
s 77483
Mr. J. C. Lank Ar. A. Ramirez
City of Austin
Electric Utility Department
721 Barton Springs Road
Mr. K. J Fiedler/Mr. M. T. Hardt
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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. 20030-5869
- Mr. G. E. Vaughn/Mr. C. A'. Johnson
Central Power & Light Company
P.O. Box 289
Mall Code: N5012
Wadsworth, Texas 77483
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STP Nuclear Operating Company'
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Records Center
700 Galleria Parkway
Atlanta, Georgia 30339-6957
Bureau of Radiation Control
State of Texas -
1100 West 49th Street
Mr. Jim Calloway
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Texas Public Utility Commiss on
- William B. Travis Building
1701 North Congress Avenue
P.O. Box 13326
John Howard, Director
Environmental arid Natural Resources Policy
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Office of the Govemor
P.O. Box 12428
Judge, Matagorda County
Matsgorda 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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ENCLOSURE 1
ATTENDANCE LIST
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PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE
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LICENSEE / FACILITY
STP Nuclear Operating Co.
South Texas Project Electric Generating Station
DATE/ TIME
December 8,1997,1 p.m. (CST)
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LOCATION
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EA NUMBER
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LICENSEE / FACILITY
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South Texas Project Electric Generating Station
DATETTIME
December 8,1997,1 p.m. (CST)
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CONFERENCE
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LOCATION
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EA NUMBER
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_. .. ' . PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE t . . LICENSEE / FACILITY STP Nuclear Operating Co, South Texas Project Electric Generating Station J DATEmME December 8,1997,1 p.m. (CST) CONFERENCE Region IV, Training Conference Room LOCATION Arlington, TX , EA NUMBER EA 97-523 NRC REPRESENTATIVES
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.. ... _ _ ._ .- -, . , PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CONFERENCE WITH HOUSTON LIGHTING AND POWER COMPANY . DECEMBER 8,1997 NRC REGION IV, ARUNGTON, TEXAS 1. INTRODUCTIONS / OPENING REMARKS REGIONAL ADMINISTRATOR 2. ENFORCEMENT PROCESS - ENFORCEMENT OFFICER 3. APPARENT VIOLATIONS & REGULATORY CONCERNS - DEPUTY DIRECTOR, DRS 4. LICENSEE PRESENTATION - - 5. BREAK (10-MINUTE NRC CAUCUS IF NECESSARY) 6. RESUMPTION OF CONFERENCE 7. CLOSING REMARKS - LICENSEE 8. CLOSING REMARKS REGIONAL ADMINISTRATOR ,l .. '
-______ __ _-_ _ _ _ _ __ _ _ _ _ _ _ _ l o o ENCLOSURE 3 ' APPARENT VIOLATIONS - _-____ -_-__________ _
-__-- -___ __ _ _ - _ . . . . . . _ . . APPARENT VIOLATIONS * 4 PREDECISIONAL ENFORCEMENT CONFERENCE HOUSTON LIGHTING AND POWER CO. DECEMBER 8,1997 ' NOTE: THE APPARENT VIOLATIONS DISCUSSED AT THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED PRIOR TO ANY RESULTING ENFORCEMENT ACTION. k, . . _ _ _ - - _ _ _ _ _ _ _ - - _ _ _
. ._ . __ _ _ __ _ _. 1 c.: . A . ' APPARENT VIOLATION . . t 1. 10 CFR Part 50, Appendix B, Criterion Ill, requires that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. South Texas Operations Quality Assurance Plan, Chapter 6.0, " Design and Modification Control, Section 5.2, states, that measures shall be established to control design activities to assure design inputs are translated into design documents such as procedures. , Contrary to the above, the licensee identified that design control measures did not assure that the calculated instrument uncertainty was isanslated to a plant operating surveillance procedure. From May 27,1994, until May 7,1997, the 3.5'F instrument uncertainty value from Calculation ZC7092, " Analysis of uncertainties for the DNB Related Parameter Tavg," Revision 0, was not correctly translated into Procedure OPSP03 ZO 0028, " Operator Logs," Revision 33, which was used to perform Technical Specification St.rveillance Requirement 4.2.5.1. 1 THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y ' BE REVISED . . .. . -
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2.' 10 CFR Part 50, Appendix B, Criterion lil, requires that design changes, including
field changes, shall be subject to design control measures commensurate with those - ' - applied to the original design. ' ' South Texas' Operations Quality Assuranca Plan, Chapter 6.0, " Design and . . Modification Control,' Section 5.5, states, that measures shall be established to t control the approval, issuance and changes of design documents to prevent the - inadvertent use of_ superseded design information. . Section 1.13 of Procedure OEP 3.070 " Preparation of Engineering Calculations,"' Revision 4, states, in part, " Design calculations which are no longer required to- _.f support design activities are to be voided . . . '." Contrary to the above, design control measures were not commensurate with those applied to the original site calculation. From June 30,1997 until September 17, - 1997, Plant Design Calculation ZC7002, " Analysis of uncertainties for the DNB-- ' Related Parameter - Tavg," Revision 0, and a vendo, supplied calculation, addressing ' the same issue for.the same parameter, summarized in Letter ST-WN HS-97-0018 . - - were both maintained in an active status. - On August 21,1997, the vendor- l - information was used to revise Surveillance Procedure OPSPO3-ZO-0028, " Operator - ' Logs," Revision 33, without voiding the site calculation and without understanding - , - the technical basis for the reduction in uncertainty. > . < ' .. 5 Q ,. lTHIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MA Y ? BE REVISED. , . < ( t t -- " 'k :_ i . .-,.- - - - . m. - . - , - . - . . . . _ - - - - - . . - - . . , , _ , . ,, , - - -
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, _ . . , 1 ' APPARENT VIOLATION i L . , L 3. 10 CFR Part 50, Appendix'B, Criterion lil, requires that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which this appendix applies are , correctly translated into specifications, drawings, procedures, and instructions. South Texas Operations Quality Assurance Plan, Chapter 6.0, " Design and Modification Control," Section 5.1 states, that measures shall be established to control design activities to assure design inputs are translated into design documents such as procedures. Contrary to the above, design control measures did not assure that the measuring and test equipment accuracy assumptions included in the process instrument uncertainty calculations were translated to process instrument calibration surveillance procedures. For example: . 1. Surveilla ice Procedures OPSP05 RC-0417, "RCS Flow Transmitter Calibration," Revision 0; and OPSP05-MS-0514L, " Main Steam Pressure Loop , Calibration," Revision 1, both required a voltmeter accuracy of 0.15 percent, when an accuracy of 0.015 percent was assumed in the associated Westinghouse uncertainty calculations. 2. Procedure OPSP06-PK-0005, "4.16kV Class 1E Degraded Voltage Relay Channel Calibration /TADOT-Channel 1," Revision 4, directed that the degraded voltage relays be tested using a test set monitor with an accuracy of plus or minus 1.0 percent of reading. An accuracy of plus or minus 0.4 percent was assumed in Calculation EC5052, " Degraded and Undervoltage Protection," Revision 3. 1_ 1 LTHIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MAY , . ,
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. ., ,. APPARENT VIOLATION , . . . 4, 10 CFR Part 50, Appendix B, Criterion ill, requires that design changes, including field changes, shall be subject to design control measures commensurate with those appl!ad to the original design. Contrary to the above, as of September 18,1997, design changes to Calculation EC5002, " Auxiliary Power System t.oad Study," Revision 4, dated October 30,1988, were not subject to design control measures commensurate with those applied to the original design. For example: 1. Design Change EC 62, dated October 16,1991, made load changes for Buses 3E171EMCE1C2 and B4 without incorporating changes made by Design Change EC-49, approved February 26,1990, causing the loss of- power loads to be incorrect. 2. Design Change EC 62, dated October 16,1991, made load changes for Bus 3E151ESGO61 A without incorporating changes made by Design Change EC-32, dated August 30,1989. Design Change EC 32 had increased load on the bus by 83 kilowatts (kW), which was not recognized by EC-62, thus, the totalload shown by EC 62 was 83 kW low. 3. Design Change PCF 176712A approved June 19,1995, made load changes to the total connected load of Bus 8E171EMOC1F2 without incorporating changes made by Design Change PFC 211205A, approved April 27,1994. 4. Design Change MDCN 90037-04, issued December 18,1995,added technical support center diesel control circuits to full-power loads, but not total connected loads or loss-of-power loads. 5. Design Change ECN 88-L-0010G, dated June 6,1989, added a 37 kW load without showing the specific changes to Calculation EC5002. . ? . THIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MA Y & BE REVISED - -
_ _ _ _ _ _ _ _ _ _ .. . . . .. . . APPARENT VIOLATION 5. 10 CFR Part 50, Appendix B, Criterion 111, requires that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
South Texas Operations Quality Assurance Plan, Chapter 6.0, " Design and Modific6An Control, Section 5.1 states that measures shall be established to document selection of design inputs. Changes to specified design inputs, including identification of their source, shall be identified and documented. Contrary to the above, as of October 20,1997, design changes were not subject to design control measures commensurate with those applied tu the original design in that changes to specified design inputs were not identified and documented. For example: 1. Design changes to the emergency diesel generator loading design basis were not identified and documented as design input changes in Study Order T 1031," Transient Voltage Response of the Diesel Ggnerator Units, Trains A, B, and C to Postulated Emergency Loading," Revision 0, issued in 1989. 2. Design changes to the auxiliary feedwater system piping configutation , were not identified and documented as design input changes in I Calculation MC5004, "AFW Suction Line Sizing and Pump Available NPSH," I - Revision 2, dated August 22,1995. Specifically, the aveitable net-positive suction head in Calculation MC5004 was calculated based on 100 feet of 6-inch piping. The latest isometric drawings show approximately 23 feet of 6-inch pipe ano 109 feet of 8-inch pipe. 3. Design changes to the expected turbine driven auxiliary feedwater pump peak discharge pressure were not identified and documented as design input changes in Calculation MC5060, " Auxiliary Feedwater Lino Sizing," Revision 1, dated December 6,1985. Calculation MC5060 was based on Revision 1 of Calculation MC5051, "AFW Pump Discharge Pressure," and did not include the changes in Revision 4 to Calculation MC5051, issued March 27,1992. 4. Design changes to the auxiliary feedwater system resistance model specified in Calculation MC5861, " Auxiliary Feedwater (AFW) Pump Design TDH and Flowrate," were not identified and documented as derign input changes in Calculation MC5864, "AFW Pump Runaut Flow," Revision 2, dated June 7, - 1989. Calculation MCS864 was based on Calculation MC5861, Revision 1, dated January 15,1987, and did not include the changes in Revision 3 to Calculation MC5861 issued July 14,1997. ' THIS APPARENT VIOLA TION IS SIJBJECT TO FURTHER REVIEW AND MA Y BE REVISED l l l . - _ _ - _ - _ _ _ _ _ _ _ _ _ - - _ _ _.
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. . ! APPARENT VIOLATION 5. 10 CFR Part 50, Appendix B, Criterion lli . . . continued 5. Desigo changes to the minimum auxiliary feedwater system flow r6quirements, maxinium auxiliary feedwater system pressure requirements and the auxilia.y feedwater system resistance model were not identified and documented as design input changes in Calculation MC5056, " Auxiliary ' Fewdwater (AFW) Control Valve Sizing; AFW System Resistance," Revision 12, dated. January 3,1986. 6. Design changes to the auxiliary feedwater system maximum pressure, the auxiliary feedwater pump curve and the auxiliary feedwater system resistance were not identified and documented as design input changes in Calculation MC5924, "Auxilia./ Feedwater Regulating Valves - Anticipated m Cycles," Revision 1, dated April 16,1987. r i
, . m Q ,. THIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MA Y ~ BE REVISED
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - . . , . O APPARENT VIOLATION 6, 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected. South Texas Operations Quality Assurance Plan, Chapter 6.0, " Design and Modification Contrr.,1," Section 5.7, states, that errors and deficiencies found in approved design documents, including design methods, that covM adversely affect the quality-related structures, systems, or components shall be documented and action taken to correct and prevent the recurrence of deficiencies. ' Chapter 13, " Deficiency Control," which applies to deficiencies discovered in activities under the scope of the operations quality assurance plan (including design control), states, that precedures shall bs developed for the control of activities i which do not conform to established requirements. These procedures shall provide for the identification and documentation of deficient conditions, resolution and/or disposition, documentation of the corrective action taken, and actions to be taken to > assure timely corrective action on deficiencies. Contrary to the above, programmatic calculation deficiencies, first identified in Observation 92-01-13, from Engineering Assurance Assessment 92-01, conducted {[ ' from January 30 through April 28,1992, and ro identified in contractor assessments completed in April and June of 1995 were not promptly corrected as follows: 1. In 1992, the technical assump* ions, contents, scopes and results of the plant design basis calculations were not consistent with the physical design of the plant. 2. In 1995,35 calculations required major revision because they wem deficient due to invalid / unverified assumptions, inconsistent format, nonretrievable referenc2s, references without revision numbers, a lack of methodology specification, a lack of instrument uncertainty consideration, a lack of consideration of calibration or process effects and/or the u_e of outdated references. These examples demonstrated a f ailure to promptly correct the problem, in that, the design basis calculation problems were identified on April 16,1992, and corrective actions were not implemented until March 3,1997. THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y y BE REVISED .. . - . - _ _ _ _ _ _ - _ _ _ _
- - . - . . . . .- - .- . . - _ - . .. . . ~ APPARENT VIOLATION. - . . - 7. 10 CFR 50.59(b)(1) requires that records be maintained of changes in the facility made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report. Further, these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. Contrary to the above, the safety analysis report was not updated and the required . written safety evaluation was not performed for Calculation MC5037,. "DeterminationNalidation of RWST Level Setpoints," Revision 7, dated July 11, 1995, which changed the facility as described on page 6.3 4 of the Updated Final Safety Analysis Report. < i THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y , . BE REVISED !. l ' _ f ? n ~ .,. ._ .,,
, . ENCLOSURE 4 LICENSE'1 PRESENTATION
_. . _ _ _ _ _ - _ - __ . i . . i v. . l SOUTH TEXAS PROJECT
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> ! PREDECISIONAL ENFORCEMENT CONFERENCE
, December 8,1997 '
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i STP: A WORLD CLASS POWER PRODUCER . , . . ! ! i. - . - -. -.. - .. -. - . - - - - - - _
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, < v .; .. i SOUTH TEXAS PROJECT ! t PREDECISIONAL ENFORCEMENT CONFERENCE
, . DECEMBER 8,1997
I ! i I i " 'i, AGENDA ! t i I Opening Remarks ............................................................... Bill Cottle
r ! l Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .. . .. . . . . . .. . . . . .. . Ted C loninger ( e . > Topics l - L - Setpoint Calculation Improvements ................................. Steve Thomas 1 - Control of Amendments .................................................... Steve Thomas i t L - Programmatic Issues ........................... Mark Kanavos & Dave Rencurrel ! . t j , L .Progr unmatic Improvements .............................................. Steve Thomas I l . t ' Overall Assessment ...................................... ...................... Ted Cloninger ! ! Perspectives Relative to Enforcement ................................. Mark McBurnett ' .
l Closing Remarks ............................................... .................. Bill Cottle i
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- ~ . , . 3 , m . SOUTH TEXAS P.ROJECT I - PREDECISIONAL ENFORCEMENT CONFERENCE ! 1 1 DECEMBER 8,1997
, 4 ! INTRODUCTION
1- 3 ! l e STP is committed to rigorously maintaining. control of desi;p . i e Inspection Report findings have been thoroughly investigated to determine l the root cause, generic implications, and safety impact j e Corrective actions and programmatic enhancements, based on the root causes, ! have been completed or are in progress for areas addressed in the Inspection
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-_ e . - ; SOUTH TEXAS PROJECT i
' PREDECISIONAL ENFORCEMENT CONFERENCE j , . DECEMBER 8,1997 ! , L
! NRC ISSUE- Setpoint calculation deficiencies not identified as conditions ! . . adverse to quality and timely corrective acdon not taken commensurate with
safety impact . . i ' DISCUSSION: '
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e In 1992 and 1993, a number ofissues regarding setpoint calculations and l instrument scaling were identified ! e Consulted industry experts to perform an independent assessment of magnitude and safety impact of the issues f - Upgrade setpoint calculations to industry standards l
- No safety impact l
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l . Established plan to address setpoint and scaling issues
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- Majority of actions completed
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. . SOUTH TEXAS PROJECT j ' PREDECISIONAL ENFORCEMENT CONFERENCE j DECEMBER 8,1997 l . CONCLUSIONS:. < !
- Initial investigations, recent assessments, and the NRC inspection continue to
support our original assessment of no safety impact . Expectation today is that this issue should have been documented as a ! condition adverse to quality j t ACTIONS: !
- Continue setpoint improvement program
j , i j e Setpoint issues have been upgraded to conditions adverse to quality t >
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. . .- .. '_ . . instrument Setpoint cnd Scaling Programs
Quakty Assurance Assessment 92-01 l - [ Hurst Review (52 calculabons 'W) Hurst independent Assessment Setpoint and Scaling Recovery Plan Hurst Setpoint Program Assessment (181 cales revewed;47 TS/SR cales.v/.; ;$) Quakty Assurance Assessment 95-04 Ergic.;;. irs Self-Assessment 4 " U V P ISA-S67.04 .Setpoint Self-Assessment Unit 1 Shutdown l 'I U ' Cr54sticci Report , Unit 2 Shutdown 9 4 Engineering Evaluaton - , , l i i 1992 1993 1994 1995 1996 1997 , = = Develop Setpoint Methodology r = = Develop Scaling Methodology = = Develop / populate Scaling Database = = Obtain WCAP Calculation Bases Documents = - Develop NSSS/ BOP Scaling Calculations , = = Develop EleGical Setpoint index Database ! Obtain Westinghouse EOP Setpoint Bases Document Create Calibration Datah% Modify Calibration Procedures ~ Revise Design Change Procedure , _ = Revise Calculation Procedure , = = 1 Evaluate Tech Spec Bases LCO L 5 7 ' t ._, - _- - . . _ .
. . . . SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997 i< 4 SETPOINT IMPROVEMENT PROGRAM SCOPE AND SCHEDULE - I NAME SCHEDULED START SCHEDULED FINISH ' Classify Setpoints 8/4/97 9/5/97 (Prelim Cc,mpicte) ! 4/1568 (Final) [
Quality Level 1 (LSSS) ! - Review Setpoint Bases 1/1268 3/6/98 Revise 3 erform New Calculations 3/9/98 6/26/98 ! Quality Level 2 (S/R other than LSSS) ! l Evaluate Setpoint Bases 2/568 7/15/98 i Revise / Perform New Calculations 2/5/98 7/1568 I ~ Quality Level 3 (Q/R) f Evaluate Setpoint Bases 7/1568 12/3168 I Revise / Perform New Calculations 7/15/98 12/3168 [, Quality Level 4 & 5 (BOP) l l Evaluate Setpoint Bases 1/1/99 7/15/00
Revise / Create new basis documents 1/1/99 7/15/00 T/S LCO Values (QL 2&3) Evaluate Bases LCO 8/467 10/24/97 (C=yletc) [ Revise / Perform New Calculations 2/5/98 12/3168 ! Process Improventents I Design Change Procedure Revisions 9/2/97 11/24/97 (cwa) t Calculation Procedure Revisions 1/5/98 4/24/98 (Complete) j
Setpoint Training 8/4/97 2/27/98 6 , r I i c --. , - - . - , - . . ,- -..- --. c ., . - . .-- .~- - ~--..-
, . . SOUTH EXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE
DECEMBER 8,1997 NRC ISSUE: Calculations with large numbers of amendments preclude f adequate design control l t DISCUSSION: l
- Amendments are procedurally controlled, reviewed, and approved changes
- Large number of mechanical and electrical design calculations - 5,268
f - 76 have more than 5 amendments i - 14 have more than 15 amendments
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- A few calculations like the Auxiliary Power System Load Study have many
l ' amendments - The Auxiliary Power System Load Study is more of a database than a computational record - The Auxiliary Power System Load Study was particularly useful tool in the early design and construction phases t ! 7 l ! i ! i . . . ' _.
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. . SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997 !
- . ! !- . j. - Relatively minor changes during operation can be controlled without this ! i tool by.using single-line electrical drawings, cable and raceway database, ! and load lists' ! i s l. - Amending the Auxiliary Power System Load Study is one of the last steps l in the change process to maintain historical record , i < - The Auxiliary Power System Load Study is needed for more complex l electrical system changes, e.g., Standby Diesel Generator digital control system upgrade
! t ) CONCLUSIONS: , 4 . Amendment process is an acceptable tool for maintaining design control .. For some calculations, a relative.large number of amendments is acceptable j -
. With the tools available today, it is practical to manage calculations without a , I large number of ar .endments ! 8 i ! I ' _ _ _ _ _ , , - . . - . _ . . _
, _ _ _ _ . . . . SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE i
DECEMBER 8,1997 l i ! '
! ACTIONS: t . e. Purchased electrical transient analysis program (software) and are modeling f the STP electrical distribution system j
e Calculation procedure revised ! - Preference for calculation revision vice amendment > - More stringent requirements for consideration of earlier amendments
. . . Actions underway to revise calculations with > 5 amendments . e ! ' i j i ' - i ! . i ! ! l
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. . . . -- - . SOUTH TEXAS PRO.iECT PREDECISIONAL ENFORCEMENT CONFERENCE
DECEMBER 8,1997
NRC IS' JE: 10CFR50.59 review not performed on calculation changes , DISCUSSION: 3 . Licensee identified that Updated Final Safety Analysis Report was not revised l for a calculation change ! , I e Calculations are not change implementing documents in and of themselves j - , . CONCLUSIONS: l 4 4 i . A 10CFR50.59 review is not required for calculation changes l - l ! ACTIONS: l
l e Revised calculation procedure requires assessment ofimpact on licensing ' basis documents when revising a calculation ' l 10 - _ ~ .-.. - .-. . . - . . m
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. . SOUTH TEXAS PROJECT i PREDECISIONAL ENFORCEMENT CONFERENCE ' DECEMBER 8,1997 e Reviewed all calculation revisions made in 1997 (25) and found no similar occurrences ! L . . Will revise Updated Final Safety Analysis Report after calculation is revised to address otherissues
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- - - e SOUTH TEXAS PROJECT t PREDECISIONAL ENFORCEMENT CONFERENCE l DECEMBER 8,1997 r ! , . NRC ISSUE: Calculations are not consistent with the as-built plant and are not j .being systematically evaluated or revised when design inputs change . e i DISCUSSION: ) ' Auxiliary Feedwater (AFW) mechanical calculations . , l - Reviewed AFW mechanical calculation examples as well as other AFW i .
mechanical calculations ! t <
- AFW mechanical calculations represent expected evolution from original l l" design through operation ' s ' . Standby Diesel Generator load study l t - Plant changes have been made since the original study i ! - Original study remains bounding l < l - Status of original study-recognized !
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_- . . _. _ _._ _ . . __ . . , . SOUTH TEXAS PROJECT
PREDECISIONAL ENFORCEMENT CONFERENCE . DECEMBER 8,1997
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i CONCLUSIONS: - ! . No revisions to AFW mechanical calculations are necessary . , l . Current Standby Diesel Generator load is bounded by existing study and no
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! ! ACTIONS: ! . Revised calculation procedure requires assessment ofimpact on other l l calculations when revising a calculation j ' . Transitioning from original Standby Diesel Generator load study to an i in-house study '
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, SOUTH TEXAS PROJECT i PREDECISIONAL ENFORCEMENT CONFERENCE ' DECEMBER 8,1997 ! < NRC ISSUE: Measuring & Test Equipment (M&TE) accuracy assumptions from calculations not correctly translated into plant procedures
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.L DISCUSSION:. ! I' .. Reviewed I&C and Electrical surveillance procedures and practices f . I&C personnel have good understanding of the impact of calculation [ j uncertainty on calibration
i . Electrical personnel understanding of uncertainty impact is not as thorough.
i However, accepted practice is to use the most accurate instrumentation ] available ,
CONCLUSIONS: , ! . Calibration procedures do not always reflect M&TE calculation assumptions > 1 . Review concluded there is no safety impact based on M&TE with appropriate . accuracies being used
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- . . 4 Sr ;TH TEXAS PROJECT i .PREDECISIONAL ENFORCEMENT CONFERENCE ' . DECEMBER 8,1997 c
, ACTIONS: 1 i . . Electrical surveillance procedures are being revised
.. Accuracy assumptions will be placed into scaling documents or electrical
. . setpoint database ! o ,
e Will train maintenance personnel on the importance of accuracy assumptions ! and the proper selection ofM&TE l l t i I 4 ! ! ! L
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SOUTH TEXAa PROJECT PREDdCISIONAL ENFORCEMENT CONFERENCE ! DECEMBER 8,1997 . r ! NRC ISSUE: Uncertainty in Reactor Coolant System average temperature not
included in surveillance procedures
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DISCUSSION: '
. Issue self-identified in Licensee Event Report 97-006 ^ . Cause was less than adequate review of the license amendment for Vantage 5H fuel upgrade e Reactor Coolant System average temperature maintained within required l limits j . Recent investigation identified that this issue has existed since 1987 l l l ! 1 l CONCLUSION:
l. . Surveillance procedures did not consider instrument uncertainty 4 ,
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. - .- . .. - SOUTH TEXAS PROJECT . PREDECISIONAL ENFORCEMENT CONFERENCE
DECEMBER 8,1997 , ! I ACTIONS. Revised surveillance procedures to include instrument uncertainties ! e ,
e Reviewed Technical Specifications Bases for similar applicability l t [ e Confirmed that other Technical Specification surveillance procedures include I proper application ofinstrument uncertainties i e Will revise Licensee Event Report 97-006 ' << ! t . i ( ' l $ $ . , i 17 i i , l
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- - SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997 ! NRC ISSUE: Failure to void a superseded calculation and using a conflicting !
vendor calculation without understanding the technical basis . DISCUSSION: . In 1987, an uncertainty calculation was performed. The uncertainty was not i applied to the Reactor Coolant System average temperature surveillance l procedure. . The issue with the Reactor Coolant System average temperature surveillance
procedure was identified in 1997. A conservative limit was used while l Westinghouse was confirming the correct limit to use . The existence of the STP uncertainty calculation was identifiedjust prior to q NRC inspection
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- . .. SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE ! DECEMBER 8,1997 l .
CONCLUSIONS: e . The correct uncertainty values were obtained from Westinghouse and were incorporated into the surveillance procedures .
- Existence of 1987 calculation was unusual
ACTIONS e Voided the unused STP uncertainty calculation l > ,
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. - .- . . - . . . . SOUTH TEXAS PROJECT l PREDECISIONAL ENFORCEMENT CONFERENCE ! , i DECEMBER 3,1997 ! l i PROGRAMMATIC IMPROVEMENTS
h e Backlog reduction j 4 1 . Modification process reduced from seven processes to one process ! . e Engineering actions tracked in Corrective Action Program
- Engineering training
l e Vendor manual upgrade program , . Purchased new tools for engineers
. - cable and raceway database
! - ANSYS finite element modeling sohare , p - Electrical transient analysis sohare
- Standby Diesel Generator transient analysis sohare ! - Transient hydraulic analysis sohare l ! L j 20 l ! 1 t , i ' . . ..
.--.- . ._ _ . . . . . _ . . -. ._ __ . . - ~ .! SOUTH TEXAS PROJECT . PREDECISIONAI, ENFORCEMENT CONFERENCE i DECEMBER 8,1997 ~ , s Filenet software facilitates page rivisions to calculations - l Folioviews software for electronic document searches ' , . - RETRAN methodology for in-house non-LOCA analyses - , . i - - BEACON software for real-time ~ reactor core monitoring j p CONTEMPT / COMPARE software for containment subcompartment -
l pressure / temperature analysis j SHUFFLEWORKS software for fuel assembly movement tracking and ' - control
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- . SOUTH TEXAS PROJECT , PREDECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997
OVERALL ASSESSMENT e Majority ofissues are historical in nature
. Inspection findings and STP investigation results are not indicative of a programmatic breakdown resulting in a loss of design control - e Actions have been taken or are in progress to correct specific deficiencies and i , to implement a number of generic enhancements j e Setpoint improvement plan is underway .
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. . . SOUTH TEXAS PROJECT
PREDECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997 ! i ! PERSPECTIVES RELATIVE TO ENFORCEMENT !
i Setpoint Calculation Deficiencies
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. Issue has been managed commensurate with the safety impact
e Comprehensive corrective action in progress , e Issue would be considered a condition adverse to quality ifidentified under l , current Corrective Action Program l ,' !
! Excessive Use Of Amendments !
- Design control is maintained by current amendment process
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- No safety impact
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. Improvements are in progress ! 1 . f i 23 ,
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__ e . SOUTH TEXAS PROJECT i PRED.ECISIONAL ENFORCEMENT CONFERENCE DECEMBER 8,1997 10CFR50.59 Review Not Performed For A Calculation Change i e Self-identified ' = No safety impact . Revised calculation procedure j . Found no similar occurrences in sample review ' Calculation Not Updated When Design Inputs Change . Auxiliary Feedwater mechanical calculations are appropriate . Design control maintained for Standby Diesel Generator loads . Enhanced calculation procedure i ! , 24 i i . . - . . . . - . .- . _ - . .- - . ,._- - .
- .. - - . . .. . SOUTH TEXAS PROJECT i PREDECISIONAL ENFORCEMENT CONFERENCE l DECEMBER 8,1997 ,
' M&TE Accuracy Assumptions Not Translated Into Plant Procedures l , . Procedural controls are not rigorous ! . No safety impact because appropriate M&TE has been used
, . Electrical surveillance procedures are bemg revised l ' . Accuracy assumptions to be added to scaling data sheets or electrical setpoint i mdex .
) Temperature Uncertainty Not Included in Surveillance I i
. Self-identified l
. No safety impact because reactor coolant temperature below the correct 1 surveillance limit ! - ! . Extensive review performed and no other similar occurrences identified ! 4
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- . - . - . . .. . . . . + &' ' SOUTH TEXAS PROJECT j PREDECISIONAL ENFORCEMENT CONFERENCE . i DECEMBER 8,1997 l , , t . . l - Failure To Void Calculation l ' e Calculation should have been voided ! . No safety impact because conservative uncertainty assumptions were used I Overall Assessment ! . s i . No programmatic breakdown of design control l Some processes need enhancement
e Current Corrective Action Program is strong
" t Need to proceed with setpoint improvement program j . l l , ! ! i l
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.. . . ..- SOUTH TEXAS PROJECT PREDECISIONAL ENFORCEMENT CONFERENCE ! DECEMBER 8,1997 . . CLOSING REMARKS = Continuous improvements being implemented by Engineering . . Management expectations have been increased along with improved performance -
- Correction action program is effective
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