IR 05000498/1987075

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/87-75 & 50-499/87-75.Closure of LER 87-22 Documented in Insp Rept 50-498/88-70

ML20247N484
Person / Time
Site:	South Texas
Issue date:	07/27/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8908030017
Download: ML20247N484 (3)

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JUL 271989 In Reply Refer To:

Dockets: 50-498/87-75 50-499/87-75 Houston Lighting & Power Cotapany ATTN: J. H. Goldberg, Group Vice President, Nuclear P.O. Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of March 24, 1988, in response to our letter and Notice of Vio'lation dated February 23, 1988. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We have reviewed the implementation of your corrective actions, completed our review of related LER 87-22, and determined that full compliance has been achieve The closure of LER 87-22 was documented in NRC Inspection Report 50-498/88-7

Sincerely, James L. Milhoan Director Division of Reactor Projects CC:

Houston Lighting & Power Company ATTN: M. A. McBurnett, Manager Operations Support Licensirg P.O. Box 289 Wadsworth, Texas 77483 Houston Lighting & Power Company  !

ATTN: Gerald E. Vaughn, Vice President )

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Central Power &' Light Company .

ATTN: R. L. Range /R. P. Verret P.0, Box 2121 ,

Corpus Christi,. Texas- 78403 City of' Austin Ele'ctric Utilit ATIN: 'R. ' J. Miner, Chief Operating

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721 Barton Springs Road Austin, Texas 78704

.Newman & Holtzinger, ATTN: ' J. R. Newman, Esquire 1615 L Street, N.W.'

Washington, D.C. 20036 Houston' Lighting & Power Company ATTN: S.-L. Rosen

.P.O. Box 28 Wadsworth, Texas- 77483-Houston Lighting & Power. Company ATTN: R. W. Chewning, Chairman Nuclear Safety Review Board P.O. Box 289

.Wadsworth, Texas 77483 City Public Service Board ATTN: R. J. Costello/M. T. Hardt-P.O. Box 1771 San Antonio, Texas 78296 Houston Lighting & Power Company

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Three' Metro Center Bethesda, Maryland 20814 Houston Lighting & Power Company ATTN: Rufus S. Scott, Associate General Counsel P.O. Box 1700 Houston, Texas 77001-

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Ro Mght c o t a;p s y P.O. Hos 1700 linuwon. 'li an 77001 (711) 22M '8211 Houston Lighting ae Power March 24 1988 ST-HL-AE-2566 File No.: G CFR2.201 U. S. Nuclear Regulatory Conunission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-496 Response to Notice of Violation 8775-01 Houston' Lighting & Power Company has reviewed Notice of Violation 8775-01 dated February' 23, 1988, and submits the attached response pursuant to 10CFR2.20 .

If you should have any questions on this matter, please contact Mr. S. M. Head at (512) 972-839 l y

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G. E. Vaughn Vice President Nuclear Plant Operatione GEV/VPE/pv Attachments Response to Notice of Violation 8775-01

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Attachment gT-HL-AE-2588 File No.: G Fase 1 of 3 South Texas Project Electric Ggnorating Station Unit 1 Docket No. STN 50-498 Response to Notice of Violation 8775-01 Statement of Violation Failure to Comply with Technical Specifications for Operability of the Chemical Detection System The South Texas Project Electric Generating Station (STFEGS) Technical Specifications (TS), Section 3.3.3.7. requires a minimum of one (1)

Chemical Detection System (CD) operable to maintain operation of the Control. Room Emergency Ventilation System for all modes of plant operation Contrary to the above requirement, the plant operated in Mode 4 during the period from December 4 to December 6,1987, with both control room toxic gas monitora in the 'Not in the Analyze Mode." This condition would have prevented the automatic iso 16 tion of the control room in the event of a toxic gas acciden ~

I Houston Llahtina & Power Position .

As stated in Licensee Event Report 87-022, HL&P concurs that the cited violation occurred. The following is a description of the even At approximately 0530 hours0.00613 days <br />0.147 hours <br />8.763227e-4 weeks <br />2.01665e-4 months <br /> on December 6, 1987 with the Unit in Mode 4 and prior to initial criticality, it was discovered that both Control Room Toxic Gas Monitors were out of service. The control room ventilation was immediately placed into recirculation mode in accordance with the requirements of Technical Specification 3.3. action statement b. At approximately 0653 hours0.00756 days <br />0.181 hours <br />0.00108 weeks <br />2.484665e-4 months <br /> both monitors were verified operational. An investigation was initiated to determine the sequence of events which resulted in both toxic gas monitors being out of servic The ensuing investigation concluded that at approximately 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on December 4, 1987 a reactor plant operator in training for cont rol room operator, incorrectly performed the required chsenel checks on both toxic gas monitors (two toxic gas monitors are used to monitor the control room Antake air). The operator issued commands through a keyboard to obtcin current readings from the Toxic Gas Monitor System but failed to return the monitors to normal service.

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Attachment ST-HL-AE-2588 File No.: G Page 2 of 3 The operatore were using two different methods to perform the Technical Specification channel check. One method was to compare night hour automatically generated printouts. The second method was to initiate, through keyboard commands, a current printout of the monitored gas reading In both methods the Toxic Gas indicating lights and trouble lights were checked for indication of possible system troubl The second method used to perform the channel check placed the computer in the summary mode. With the computer in the summary mode, the actuation function of the monitors is disabled. When the monitor is returned to normal operation the monitoring resumes. Indiesting and status lights remain in their normal configuration throughout this method of channel chec If a keyboard error is made in returning the monitors to service, the indicating and status lights will remain in their normal configuratio The operators who performed subsequent channel checks did not recognize that the monitors were out of service because the monitors continued to printout data even though the data was not meaningful and indicating lights remained normal. The monitors were determined to be inoperable when one of the operators recognized that the readings differed from previous channel checks he had performe The NRC was notified of the occurrence at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br /> on December 7, 198 II Reason for Violation The root causes of this violation are a failure to provide adequate training on the operation of the Toxic Gas Honitoring System equipment and the performance of channel checks, lack of positive indication of system status, and lack of procedural guidanc I Corrective Action Taken and Results Achieved The following corr 6ctive actions have been taken in response to this violation: Houston Lighting & Power Company (HL6P) reported this event pursuant to 10CFR50.72 and submitted Licensee Event Report 87-022 (see correspondence ST-HL-AE-2471, dated January 7, 1988) pursuant to 10CFR50.7 . The Toxic Gas Honitors have been reprogrammed such that operators will not be required to manipulate the system to perform channel check NL.88.077.01

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Attachment ST-HL-Ag-2588 File No.: G Fage 3 of 3 3. Additional training was conducted on the proper operation and use i of the Toxic Gas Monitors for tlnit 1. HL&P has reviewed and l revised, as necessary, the on-the-job training program for operator rounds and channel checks in general to ensure effectiveness of trainin . The log keeping procedure was revised to provide adsquate instructions for performing channel checks on the Toxic Gas Monitors. HL&P has reviewed and revised, as necessary, other operator logs for channel check requirement t 5. HL&P has evaluated the feasibility of a positive method for I detennining the operability of the Toxic Gas Monitoring syste Separate annunciator windows will be provided in the control room for the HI toxic gas signal and the Malfunction / Loss of Power signals. This modification will be completed prior to restart from the next refueling outag . Plant briefings were conducted and the Plant Conduct of Operations procedure was revised to specifically designate how trainees can be use Corrective Steps Taken to Prevent Recurrence The actions described in section IV above will prevent recurrence of this violatio V Date of Full Compliance HL&P is in full compliance at this time. AddJtional plant improvements will be completed prior to restart from the next refueling outage.

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NL.88.077.01