ML20199J535
| ML20199J535 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/21/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20199J541 | List: |
| References | |
| 50-498-97-24, 50-499-97-24, EA-97-523, NUDOCS 9711280163 | |
| Download: ML20199J535 (7) | |
See also: IR 05000498/1997024
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November 21,1997--
lEA 97 523
William T. Cottle, Group Vice
President, Nuclear
Houston Lighting & Power Company
P.O. Box 289 -
Wadsworth, Texas 77483
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SUBJECT: NRC INSPECTION REPORT 50 498/97-24; 50-499/97 24
Dear Mr. Cottle:
From September 15 through November 12,1997, the NRC inspected your design control
program and the adequacy of calculations used to develop the design and licensing basis
for your South Texas Project Electric Generatlng Station Units 1 and 2, reactor facilities.
The team reviewed the history and corrective actions ass:iated with previously identified
weaknessos related to the process instrument setpoint and scaling program. The team also
reviewed 10 CFR Part 50.59 saf ety evaluations and 10 CFR Part 50.59 applicability
screening evaluations,
We have concluded that t,nreviewed safety question evaluations and screenings were
generally logical and of good quality. However, we identified design and licensing control
concerns, which are discussed below. We noted that, as time permitted, your staff
initiated and plaaned corrective actiuns for the weaknesses identified by the team.
We have concluded that your current setpoint guidance procedure was technically
adequate. However, a random sampling of existing calculations for safety-related plant
process values indicated that appropriate uncertainty calculations had not always been
accomplished through the end of 1996. The team selected 6 safety related process valucs
from the Updated Final Safety Analysis Report and found that calculations associated with
4 of the 6 p'rocess values were incorrect and required revision. We also continued to
identify problems with the basis for setpoints. Three of 20 setpoints, which had been
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identified by your contractor in 1995 as potentially having no basis, still had weak-
calculation bases. The unresolved item related to our review of the safety impact of your
decision to defer planned setpoint program improvements was left open for additional
review. The NRC plans to evaluate the calculations, which address team concerns, but
were not complete at the conclusion of the inspection. The specific technicalissues are
discussed in Section E8.2 of the enclosed report.
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Based on the results of this inspection seven apparent violations were identified and are
being considered for escalated enforcen.ent action in accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
NUREG-1600. The team identified one apparent violation of 10 CFR Part 50, Appendix B,
Criterion XVI, " Corrective Action," five apparent violations of 10 CFR Part 50, Appendix B,
Criterion lil, " Design Control," and one apparent violation of 10 CFR 50.59, " Changes,-
Tests and Experiments." No Notice of Violation is presently being issued for these
inspection findings, in addition, please be advised that the number ano characterization of
apparent violations described in the enclosed inspection report may change as a result of
further NRC review.
The NRC is concerned about the apparent corrective action violation because it appeared
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that your threshold for determining that calculation deficiencies are conditions (iverse to
quality was too high. As a result, you did not take corrective action in a time frame
commensurate to the safety significance of design deficienc'es first identified in 1992. The
NRC is concerned about the apparent design control violation related to the control of
amendments because your enginers may not have been provided with the tools required to
adequatoly maintain thc design of tu f acility. As a result, in some cases calculations were
amended so many times, that the bu ding design values were not readily apparent. The
NRC is concerned about these violatio.is, the remaining apparent design control violations
and the 10 CFR 50.59 violation, because the causes appear to be programmatic. As such,
the team has probably not identified all of the examplea ano may not have identified the
most safety significant examples.
A predecisional enfercement conference to discuss these apparent violations has been
scheduled for December 8,1997. The decision to hold a predecisional enforcement
confereme does not mean that the NRC has determined that a violation has occurred or
that enforcement action will be taken. This conference is being held to obtain 3. formation
to enable the NRC to make an enforcement decision, such as a common understanding of
the facts, root causes, mined opportunities to identify the apparent violation sooner,
corrective actions, significr :e of the issues, and the need for lasting and effective
corrective action. During the predecisional enforcement conference, we expect you to
describe your current plan and schedule for identifying and correcting any remaining
calculation deficiencies, in addition, this is an opportunity for you to point out any errors in
our inspection report and for you to provide any information conceming your perspectives
on 1) the severity of the violations,2) the application of the f actors that the NRC considers
when it determines the amount of a civil penalty that may be assessed m accordance with
Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement
Policy to this case, including the exercise of discretion in accordance with Section Vll.
This coc!erence will be open to public observation in accordance with a recent change to
the enforcement policy (61 FR 65088).
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding these apparent violations is required at this time,
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter -
and its enclosure will be placed in the NRC Public Document Room (PDR).
- Should you have any que:tions concerning this inspection, we will be pleased to discuss
them with you.-
Sincerely,
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Arthur T. Howell lil, Director
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Division of Reactor Safety
Docket Nos.: 50 498;50-499
License Nos.: NPF 76; NPF 80
- Enclosure:
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NRC Inspection Report
50-498/97-24; 50 499/97 24
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cc w/ enclosure:
Lawrence E. Martin, General Manager
Nuclear Assurance & Licensing
Houston Lighting & Power Company
P.O. Box 289
Wadsworth, Texas 77483
Mr. J. C. Lanier/Mr. M. B. Lee
~ City of Austin
- Electric Utility Department
721 Barton Springs Road
Mr. K. J. Fiedler/Mr. M. T Hardt
City Public Service Board
P.O. Box 1771
San Antonio, Texas 78296
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-Jack R. Newman,- Esq.
1800 M. Street, N.W.
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Washington, D.C. 20036 5869
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Houston Lighting & Power Company-
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Mr. G . E. Vaughn/Mr. C. A. Johnson
Central Power & Light Company
P.O. Box 289.
Mail Code: N5012
Wadsworth, Texas 77483
Records Center
700 Galleria Parkway
- Atlanta, Georgia 30339-5957
Dr. Bertram Wolfe
15453 Via Vaquero
Monte Sereno, California 95030
Bureau of Radiation Control
State of Texas
1100 West 49th Street
Mr. G!enn 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 -
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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Rufus S.4 Scott, Associate'-
- General Counsel
Houston Lighting & Power Company-:
P.O. Box 61867 '
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Houston, Texas 77208
-' Joseph R. Egan, Esq.
Egan & Associates,- P.C. .
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- 2300 N Street, N.W.
Washington, D.C.- 20037
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