IR 05000498/1992035
| ML20045E457 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/25/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9307020131 | |
| Download: ML20045E457 (5) | |
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UfelVED STATES
[pH Mf GgIg NUCLEAR aEGULATORY COMMISSION
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' REGION IV
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G11 RYAN PLAZA DRIVE, SUITE 400 o
AR LINGTON, T E X AS 76011-8064
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JUN 2 51993 Dockets:
50-498 50-499 Licenses: NPF-76 NPF-80 Houston Lighting & Power Company
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ATTN: William T. Cottle, Group Vice President, Nuclear P.O. Box 1700 Houston, Texas 77251 SUBJECT:
NRC INSPECTION REPORT 50-498/92-35; 50-499/92-35 RESPONSE We acknowledge your response to our letter dated April 29, 1993, which provided supplemental information related to our letter and Notice of Violation dated March 3, 1993.
We have also reviewed-your response to the first example of Violation 9235-02. As we stated in our last letter to you involving this matter, regardless of whether the foreign material in the fuel oil strainer met your definition of a condition adverse to quality, it
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nonetheless constituted a. problem associated with a significant piece of safety-related equipment that should be investigated, analyzed, and corrected to preclude recurrence.
Thus, our position remains unchanged.
Your corrective action program is the vehicle that is presently in place to accomplish these activities and we encourage you_to actively pursue enhanced utilization of this program in order to improve your documented past poor performance in correcting problems.
Your staff, as well as the NRC staff, has expended sufficient time and resources discussing and documenting this matter.
This amount of
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correspondence on this particular issue ind cates to us that your staff has
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not fully developed the necessary sensitivity, rigor, and initiation threshold for documenting problems using your corrective action program. We point out that on May 18, 1993, this same emergency diesel generator suffered a valid failure, due to conditions similar to the conditions identified in the first example of Violation 9235-02.
We have also reviewed the additional information provided for the second and third examples of Violation 9235-02 and find it responsive to the concerns-raised in our Notice of Violation. We will review the implementation of your 9307020131 930625 PDR ADDCK 05000498 O
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Houston Lighting & Power Company-2-
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corrective actions for these. issues during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely,
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d Bill Beach, Director
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Division of Reactor Projects cc:
Houston Lighting & Power Company ATTN: William J. Jump, General Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483
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City of Austin Electric Utility Department ATTN:
J. C. Lanier/M. B. Lee 721 Barton Springs Road Austin, Texas 78767
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City Public Service Board ATTN:
R. J. Costello/M. T. Hardt
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P.O. Box 1771 San Antonio, Texas 78296 I
Newman & Holtzinger, P. C.
ATTN:
Jack R. Newman, Esq.
1615 L Street, NW
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Washington, D.C.
20036 Central Power and Light Company
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ATTN:
D. E. Ward /T. M. Puckett P.O. Box 2121 Corpus Christi, Texas 78403 INPO Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957 Mr. Joseph M. Hendrie 50 Bellport Lane Bellport, New York 11713
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Houston lighting &' Power CompanyE-3-l Bureau of. Radiation Control t
State of Texas
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1101-West 49th' Street-
Judge, Matagorda County
Matagorda County Courthouse 1700 Seventh Street
' Bay City,. Texas 77414
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Licensing Representative Houston Lighting & Power Company
Suite 610
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Three Metro Center Bethesda, Maryland 20814
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Houston Lighting & Power Company ATTN: Rufus S. Scott, Associate General Counsel
P.O. Box 61867
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Houston,. Texas 77208
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J. L. Milhoan Resident Inspector Section Chief (DRP/TSS)
Section Chief (DRP/A)
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Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System
DRSS-FIPS RIV File Project Engineer (DRP/A)
R. Bachmann, 0GC, MS: 15-B-18
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J. L. Hilhoan Resident Inspector
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The Light
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c o m p a n ySouth Texas Project Electric Generating Station P.O. Box 289 Wadsworth. Texas 77483
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O May 11, 1993 ST-HL-AE-4434 i
File No.:
G02.04
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10CFR2.201 U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Supplemental Reply to Notice of Violation 9235-02 Regarding Failure to Promptly Identify and Correct Conditions Adverse to Ouality Reference 1): Correspondence from W. H. Kinsey, Jr. (HL&P) to NRC Document Control Desk, dated April 2, 1993 (ST-HL-AE-4388)
Reference 2): Correspondence from A. Bill Beach (NRC) to William T.
Cottle (HL&P), dated April 29, 1993 (ST-AE-HL-93393)
In Reference 1), Houston Lighting & Power (HL&P) committed to provide a supplemental report on the Notice of Violation because evaluation of the failure to take prompt corrective actions to resolve a recurring deficiency identified in essential chiller 21A was not complete. The evaluation is now complete and the results have been included in the Attachment, annotated by change bars.
As confirmed in Reference 2), HL&P committed by telephone to provide additional information concerning the third example of Violation 9235-02, Auxiliary Feedwater Pump 24 overspeed trip mechanism.
The additional information is also included in the Attachment, annotated by change bars.
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IRn91-131.003 Project Man:Eer on Behalf of the Participanu in the South Texas Project
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Houston Lighting & Power Company South Texas Project Electric Generating Station
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ST-HL-AE-4434 File No.:
G02.04-Page 2 Finally, justification for our position that foreign material on the SDG fuel oil strainer does not represent a condition adverse to quality has been added and annotated with change bars.
If there are any questions regarding these matters, please contact Mr. A. W.
Harrison at (512)
972-7298 or me at (512) 972-7921.
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4 W. H. Kinsey, Jr.
Vice President, Nuclear Generation
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JTC/sr Attachment:
Supplemental Reply to Notice of Violation 9235-02
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2RW313L001
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ST-HL-AE-4434 Houston Lighting & Power Company South Texas Project Electric Generating Station File No.: G02.04
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Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P.
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Box 61867 Houston, TX 77208 Lawrence E. Kokajko Project Manager U.S. Nuclear Regulatory Commission Institute of Nuclear Power Washington, DC 20555 13H15 Operations - Records Center 70U Galleria Parkway J.
I. Tapia Atlanta, GA 30339-5957-
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Senior Resident Inspector.
c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P.
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Bc:: 310 Bellport, NY 11713 Bay City, TX 77414 D. K.
Lacker J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C., STE 1000 Texas Department of' Health
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1615 L Street, N.W.
1100 West 49th Street-Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M.
Puckett U.S. Nuclear Regulatory Comm.
Central Power and Light Company Attn:
Document. Control Desk P.
O.
Box 2121 Washington, D.C.-
20555 Corpus Christi, TX 78403 J. C. Lanier/M. B. Lee City of Austin
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Electric Utility Department 721 Barton Springs Road Austin, TX 78704 K. J. Fiedler/M. T. Hardt City Public Service P. O.
Box 1771 San Antonio, TX 78296
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Attachment ST-HL-AE-4434 Page 1 of 4 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION 9235-02 I.
Statement of Violation:
Criterion XVI to 10 CFR 50, Appendix B, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material, and nonconfo'mances are r
promptly identified and corrected. In the case of significant
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conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Procedure OPGP03-ZX-0002, Revision 0, " Corrective Action Program," Section _4.1, Station Problem Report Instruction, requires that, "any person at STPEGS who identifies or becomes aware of a Condition Adverse
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to Quality (CAQ) or Significant Condition Adverse to Quality (SCAQ) SHALL promptly document the occurrence using an SPR
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Form."
Four examples of violating these requirements are stated below:
1. Contrary to the above, a station problem report _was not promptly initiated to document the foreign material (rust like particles) found on the Emergency Diesel Generator 23
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fuel oil strainers on December 4, 1992. This. nonconforming condition was identified during the performance of Service Request DO-186915 to replace the strainers.
2. Contrary to the above, prompt corrective actions were not initiated to correct equipment deficiencies with Essential Chiller 21A.
Plant Equivalency Change CH-178119 was initiated in June 1992 to correct a condition which permitted the upper oil reservoir to migrate to the lower reservoir, requiring the essential chiller to be declared inoperable in accordance with Technical Specification 3.7.14. On December 9,1992, the Essential Chiller 21A was declared inoperable because the essential chiller did not have sufficient indicated oil level showing in the upper reservoir. Plant Equivalency Change CH-178119 had not been initiated and no date had been established for implementing the plant equivalency change.
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Contrary to the above, as of December 17, 1992, the licensee had not identified the cause for the repetitive problems with Auxiliary Feedwater Turbine 24 overspeed trip mechanism and had taken no corrective actions to preclude the recurrence of the problem.
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Attachment
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ST-HL-AE-4434
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Page 2 of=4 I.
Statement of Violation: (cont'd)
4. Contrary to the above, the corrective action taken to a violation documented in NRC Inspection Report 50-498/91-11; 50-499/91-11 involving individuals working more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, was not adequate to preclude repetition.
During,the inspection, four individuals were identified to have - exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> worked in a 7-day period without plant manager approval.
One occurrence involved an instrumentation and controls technician, with three additional occurrences involving electrical maintenance personnel.
These four examples constitute one Severity Level IV violation. (Supplement I) (498;499/9235-02)
II.
Houston Lichtina & Power Position:
HL&P concurs that the cited violation occurred, but does not agree that the fuel oil strainer example represents a condition adverse to quality. The fuel oil system is designed and maintained to minimize water and sediment in the fuel oil.
Periodic drainage of water accumulation, the use of high quality fuel, and keeping the fuel oil tanks full assures that internal corrosion and algae growth will be minimal. Fuel oil is sampled periodically and verified that particulate contamination is within limits. However, there are six filters or strainers in the system between. the Auxiliary Fuel Oil
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Storage Tank (in the yard) and the fuel injectors - on the diesel engine to assure that the fuel is clean. The solids found on the strainer elements in question had built up slowly over a two-year period of normal operation. Therefore, since it is normal for the strainer to collect trace amounts of solids from the fuel and the strainers were performing their function, this does not represent a condition adverse to-quality.
III. Reason for Violation:
The cause of the second example, essential chiller 21A modifications was a lack of sensitivity to the significance of the chiller modifications in establishing implementation priority.
The cause of the third example, Auxiliary Feedwater Pump 24 overspeed trip mechanism, was that the system engineer did not consider the various f ailures as indicators of a different and larger problem. The evaluation was not given high enough priority to completely investigate and resolve the real problem.
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Attachment
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ST-HL-AE-4434 Page 3 of 4 III. Reason for Violation: (cont'd)
The fourth example, the adverse trend involving overtime exceedance, was caused by a lack of training on the detailed requirements of the Administrative Technical Specification governing overtime. Most of the exceedances occurred because personnel assumed that the requirement was based on a fixed seven-day schedule instead of a rolling seven-day time period.
IV.
Corrective Actions:
The modifications noted in the Inspection Report have been implemented for essential chillers in both Units except for changing the evaporator pressure switch setpoint on chiller 21C. This is scheduled to be completed prior to the end of the Unit 2 refueling outage.
Throughout the conduct of operational readiness reviews that HL&P has implemented for startup of Unit 1 from the current forced outage, Operations and Engineering personnel have been reevaluating the potential safety impact of open Service
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Requests, design modifications, temporary modifications,.and other engineering backlog items on equipment operability, safe plant operation, and operator work-arounds.
The evaluations-and the presentations made before the Senior Management Panel have been educational regarding increasing sensitivity to the i
significance to safe operations of modifications and other work.
This process will continue in preparation for the startup of Unit 2.
HL&P will continue to emphasize with Operations, Maintenance, and Engineering-personnel the identification and effective corrective action for plant equipment problems.
The physical corrective actions involved with the third example, Auxiliary Feedwater Pump 24 overspeed trip mechanism, included cleaning the trip reset plunger and changing from Mobil Vaprotec Light oil to Mobil DTE 797, which is compatible
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with Vaprotec. The generic corrective actions are described in the next paragraph.
The generic implications of the equipment conditinn have also been considered.
The program to analyze and trend equipment history to identify repetitive component degradations and failures will be upgraded to provide for more prompt and effective action to prevent recurrence.
(Corrective action will commence by April 15, 1993, and will be completed by December 15, 1993.)
Additionally, training will be conducted to increase personnel awareness of 'the definition of non-conforming conditions and the necessity of prompt corrective action.
Appropriate plant procedures will be revised to include specific examples of non-conforming conditions and IR\\93-131.001
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Attachment
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ST-HL-AE-4434 Page 4 of 4 IV.
Corrective Actions: (cont'd)
specific instructions for dealing with non-conforming Service Requests. The Service Request Form will be revised to ensure the clear indication of a
non-conforming condition.
(Completion Date: June 30, 1993).
To correct the fourth example, a
memo was issued to Maintenance Department Personnel to ' reemphasize the STPEGS Overtime Policy.
The Overtime Exceedance Policy (OPGP02-ZA-0060) will be replaced by OPGP03-ZA-0116 to clearly define management expectations regarding compliance with Administrative Technical Specification requirements. Training will be conducted on the new procedure.
(Completion Date:
June 10, 1993.)
V.
Date of Full Compliance:
HL&P will be in fu,11 compliance on December 15, 1993.
In the interim, the necessity for initiating an SPR to fully investigate apparent adverse trends in equipment condition will be emphasized to station personnel.
IR\\93-131.001