IR 05000498/1990031
| ML20058D380 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/01/1990 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hall D HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20058D381 | List: |
| References | |
| EA-90-164, NUDOCS 9011060077 | |
| Download: ML20058D380 (5) | |
Text
)
["%,g i
UhtTLo sT ATES
.
NUCLEAR REGULATORY COMMISSION
y*
'g
,,
I i
- !
RtGloN IV D
f 611 RYAN PLAZ A oRIVE, SUlTE 1000
\\-
,E ARLINGTON. TEXAS 78011 NOV -l 1990 Docket Nos. 50-498 and 50 499 License Nos. NPF-76 and NPF-80 i
EA 90 164 i
Houston Lighting & Power Company ATTN: Donald P. Hall, Group Vice Fresident, Nuclear Post Office Box 1700 Houston, Texas 77251 Gentlemen:
j SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 90-31)
This rcfers to the inspection conducted September 12-21, 1990, at Houston Lighting & Power Company's South Texas. Project (STP) and to the discussions of the results of that inspection with you and other HL&P representatives at an enforcement conference in the NRC's Arlington. Texas office on October 5,1990.
The NRC's inspection report was issued on September 26, 1900.
On September 12, 1990 STP entered Mode 3 Hot Standby, and proceeded to heat up to 385 degrees Fahrenheit (F) before realizing that one of the plant's three l
High Head Safety Injection (HHSI) pumps was inoperable becaure its electrical breaker was rocked out. This was a violation of Technical Specification (TS) 3.0.4 and 3.5.2, that reouire all three Emergency Core Cooling System (ECCS)
i subsystems to be operable before the Reactor Coolant System (RCS) cold leg temperature exceeds 375 degrees F.
The violative condition existed for only 15 minutes before ycur plant operating personnel detected it and for a total i
of 22 minutes before it was corrected by restoring the pump to operable status.
This TS violation appears to have occurred as the result of poor communications
'
l between operating personnel, poor command and control exercised by tM unit supervisor, and a failure to pay strict attention to the temperature limits associated with restoring the operability of the HHSI pumps curing plant heatup.
'
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2. Appendix C (1990), a l
violation of this type would normally be catecorized at Severity Level III
.
(SupplementI,exampleC.I.a).
However, the NRC recognizes that, unlike all other U.S. nuclear plants that have only two independent trains of ECCS, both units at STP have three independent trains of ECCS, two of which were operable throughout this event.
In addition, til three Low Head Safety Injection sub-systems were available and the plant was at reduced temperature and pressure and the NRC accepts HL&P's analysis that sufficient cooling-capability was available or could have been made available should it have been necessary. Therefore, the NRC recognizes the relatively low safety significance of the TS violation.
9011060077 901101 PDR ADOCK 05000498 Q
.-
.
._
,
...
_
..
..
-
- --.-- -
_
.
.. _. _
_.__
__
. _ _
'
.
..
,
.
,
.
Houston Lighting & Pcwer Company-2-Nonetheless, this violation is of concern to the NRC because it and other relatively recent events at STP appear to have resulted from personnel error and inattention to detail on the part of plant employees, and also appear to indicate a departure from what NRC had considered to be good performance on the part of the plant operating staff. Specifically, similar weaknesses in control room communications were observed by NRC personnel who conducted requa-lification examinations of STP operators in March 1990 and were documented in an April 27, 1990, letter to you.
In addition, the NRC issued a Notice of Violation to HL&P on September 18, 1990, for a violation involving a failure to properly align valves associated with an STP Unit 1 auxiliary feedwater pump, a personnel error which resulted in the pump being unavailable following a plant trip on July 30, 1990. This violation was attributed to a failure of plant personnel to conduct the required independent verification of the valve lineup.
'
The personnel errors associated with the September 12,1990, event, errors associated with other events occurring in 1990, and the NRC's concerns about these were discussed with HL&P's representatives at the enforcement conference.
The causes and contributing factors associated with these events vary, but most
involve inattention to detail to some degree. The NRC is primarily concerned with your organization identifying and correcting the cause or causes of this i
disturbing trend and reversing it.
You ano other HL&P representatives at the enfo cement conference described a performance improvement program at STP that is designed to instill in STP employees a heightened sense of ownership and accountability, a program that HL&P develeped on its own initiative in response to its recognition that person-nel errors and procedural infractions were on the rise. The NRC encourages HL&P L
to implement this program with vigor and to address other factors, such as maintenance backlogs or other plant conditions, that may have contributed in some cases to the likelihood of errors being made.
Based on the considerations discussed above, the violation in the enclosed Notice has been classified at Severity Level IV. However HL&P should be aware
,
'
L that repetitive violations of this nature may lead to monetary civil penalties, enforcement action against licensed operators or other escalated enforcement l
action, as deemed appropriate.
'
,
You are required to respond to this letter and should follow the instructions I
!-
specified in the. enclosed Notice of Violation (Notice) when preparing your response.
In your response, you should document the specific actions taken I
and any additional actions you plan to prevent recurrence. After reviewing l
your response to this Notice, including your proposed corrective actions and-the results-of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure the continued safe operation of STP.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
.
this letter and its enclosures will be placed in the NRC Public Document Room..
.
In addition to the Notice, a copy of HL&P's enforcement conference handout and a list of enforcement conference attendees are enclosed. The responses
- -
.
.
-
- -
.-
. -
-. -.
.
. -.
.
-
- -,
-
a
,
i
.
.
.
.
.
.
Houston Lighting & Power Company-3-
directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of_ Management and Budget as required by the Paperwork Reduction Act of 1980. Pub. L. No.96-511.
Sincerely, d Q f)Q&E I
-
Robert D.
)
Regional s r, gor Enclosures:
1.
HL&P's enforcement conference handout 3.
List of enforcement conference attendees cc w/ enclosures:
Houston Lighting & Power Company ATTN:
M. A. McBurnett, Manager Operations Support Licensing P.O. Box 289 Wadsworth Texas 77483 City of Austin Electric Utility Department ATTH:
J. C. Lanier/M. B. Lee l
P.O. Box 1088
'
"
!
City Public Service Board ATTN:
R. J. Costello/M. T. Hardt P.O. Box 1771 l
San Antonio, Texas 78296 Newman & Holtzinger, P. C.
'
ATTN: Jack R. Newman, Esq.
1615 L Street, NW Washington, D.C.
20036 Central Power and Light Company ATTN:
R. P. Verret/D. E. Ward P.O. Box 2121 Corpus Christi, Texas 78403
'
INP0 Records Center 1100 Circle 75 Parkway Atlanta, Ceorgia 30339-3064
,
. -,..
,m
_ _ _ -, _ _ _ _ _ _ _
-
'
'
...
..
.
.
..
' Houston Lighting & Power Company-4-Mr. Joseph M. Hendrie 50 Bellport Lane l
De11 port, New York: 11713 Bureau of Radiation Control State of Texas 1101. West 49th Street Austin, Texas 78756 Judge, Matagorda County.
Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 Licensing Representative
'
,
Houston Lighting & Power Company Suite 610
'
. Three Metro Center Dethesda, Maryland : 20814 Houston-Lighting &. Power Cor;any ATTN:
Rufus S. Scott, Associate General Counsel P.O. Box 61867 i
Houston, Texas 77208
i
-
b h
l i
,
..
..
.
.
-
.
' 6 g -l g "
.m.a.
.
,
.
.
.
'
.
.
~
Houston Lighting & Power Company-5-o i
DISTRIBUTION:.
<
masusA1501)
'
SectionChief(DRP/D)'
G. F. Sanborn
.
'
DRS-
?
MIS System a.
-DRSS-FRPS'
i Lisa Shea, RM/ALF
,
RIV' File
,
R.;Bachmann, OGC
'
RSTS Operator
=ProjectEngineer(DRP/D)
LPDR'
-SECY CA-
.
JSniezek, DEDR JLieberman, OE RDMartin, RIV-
-
-JGoldberg,'0GC
-"
TMurley, NRR U-
'JPartlow, NRR-
_
Enforcement Coordinators
'RI, RII, RIII -RV:
l Resident-Inspector
'
FIngram,GPA/PA:
BHayes, 01
_
DWilliams. 0lG
?g ",
.,
,
- EJordan, AEOD-
. <v uw~
J,a
! /
RPedersen,'OE'
/
G
,
, Day File e 7,
'
...
LEA File r
- DCS
l
^
I'
s
,,
- \\f
,,' ',, V
.
- .
i
.
e-t
.
.
- RIV:E0~
C
- D:DRP DRS-D RA OE-
,
'GFSanborn;ap - W r wn SJCollins LJCallan JM ntgomery RDMartin JLieberman
- 10/11/90'
/ /
10/12/90 10/15/90 10/16/90 10/17/90 10/30/90
'
,j
'
,
e
,
,
,
<
.
--