ML20197F346

Notice of Violation from Insp on 971112.Violations Noted: Programmatic Calculation Deficiencies,First Identified in Observation 92-01-13 Not Promptly Corrected

ML20197F346
Person / Time
Site:	South Texas
Issue date:	12/22/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20197F312	List: ML20197F306 ML20197F346
References
50-498-97-24, 50-499-97-24, EA-97-523, NUDOCS 9712300192
Download: ML20197F346 (5)

Text

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NOTICE OF VIOLATION i

. STP Nuclear Operating Company Docket Nos. 50-498; 50-499 i South Texas Project Electric Generating License Nos. NPF-76; NPF-80 EA 97 523 During an NRC inspection completed November 12; 1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A.- 10 CFR 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 Control," Section 5.7 states that errors and deficiencies found in approved design documents, including design methods, that could 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 procedures shall be developed for the control of activities 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 cos,ective 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 re-identified in contractor assessments completed in April and June of 1995 were not promptly corrected as follows:

1. In 1992, the licensee identified that the technical assumptions, 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 were deficient due

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to invalid / unverified assumptions, inconsistent format, non-retrievable references,-

references without revision numbers, a lack of methodology specification, a lack

.of consideration of calibration or process effects and/or the use of outdated references.

These examples demonstrated a failure to promptly correct the problem, in that the

. design basis calculation problems were identified on April 16,1992 and actions to correct these progrmmatic calculational deficiencies were not initiated until March 1997, with

.. completion planned by December 1998. (01014)

This is 'a Severity Level IV violation (Supplement I) (50-498;-499/9724-06).- ,

9712300192 971222 PDR ADOCK 05000498

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2-B. 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

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 support design activities are to be voided.. "

Contrary to the above, the NRC identified that 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 vendor supplied calculation, addressing the same issue for the same parameter, summarized in letter ST-WN HS-97-0018, dated June 30, 1997, were both maintained in an active status. On August 21,1997, the vendor information was used to revise the Surveillance Procedure OPSP03-ZQ-0028, " Operator Logs," Revision 33, without voiding the site calculation. (02014)

This is a Severity Level IV violation (Supplement 1) (50-498;-499/9724 08).

C. 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

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, as of November 21,1997, the NRC identified surveillance procedures which were not appropriate to the circumstances. Measuring and test equipment accuracy assumptions included in the process instrument uncertainty calculations were not correctly translated into the following process instrument calibration procedures:

1, Surveillance 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 EC-5052," Degraded and Undervoltage Protection,"

Revision 3. (03014)

This is a Severity Level IV violation (Supplement 1)(50-495;-499/9724-01).

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D. 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.

STP Operations Engineenng Procedure OEP 3-070, Revision 4

• Preparation of Engineering Calculations," Attachment OEP-3-070 01, states, in part, that "A revision to a calculation shall be issued when any of the following guidelines have been satisified or as directed by the DM and shall follow the requirements as given in Section 6.0 of this procedure . . When it is determined that amendment changes are ;xtensive and lack of incorporation could cause misunderstanding (as determined by the responsible SE), a DCN/MDCN/ECN should not be issued for this case "

Contrary to the above, as of September 18,1997, the NRC identified that design changes to Calculation EC 5002," Auxiliary Power System Load Study," Revision 4, dated October 30,1988 were not subject to design control measures commensurate with those applied to the original design. The NRC also determined that the licensee did not comply with Procedure OEP 3-07Q with respect to this calculation, in that amendment changes were extensive and lack of incorporation resulted in erroneous information that could cause misunderstanding. 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 3E151ESGOE1 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 total load shown by EC-62 was 83 kw low.

3. Design Change PCF 176712A approved June 19,1995, made load chanjes to Bus 8E171EMOC1F2 total connected load without incorporating changes made by Design Change PFC 211205A, approved April 27,1994.

4. Design Change MDCN 90037-04, issued December 18,1995, added a 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 by cover sheet without showing the specific changes to calculation EC-5002.

(04014)

This is a Severity Level IV violation (Supplement I)(50-498,499/9724-02).

E. 10 CFR 50.71(e) requires that the Updated Final Safety Analysis Report include the effects of all changes made ir$ the facility as described in the Final Safety Analys;s Report.

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Contrary to the above, on July 11,1995 Revision 7 of Calculation MC-5037,

" Determination / Validation of RWST Level Setpoints," changed the facility as described in the safety analysis report and the safety analysis report was not updated. For example, Calculation MC-5037 specified that the design margin allowed for instrument uncertainty associated with the tank level transmitter was 4.38 percent of instrument span or 23,469 gallons. This was less than the 5 percent or 26,550 gallons allowed for tank level instrument uncertainty in Updated Final Safety Analysis Report Section 6.3.2.2,

" Equipment and Component Descriptions; Refueling Water Storage Tank."(05014)

This is a Severity Level IV violation (Supplement 1)(50-498;-499/9724-05).

Pursuant to the provisions of 10 CFR 2.201, STP Nuclear Operating Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington. Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation' and should include for each virlation: (1) the reason for the violations, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, youJnust specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personai privacy or provide the information rcquired by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information) If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas thisJhad day of December 1997