IR 05000498/1993005
| ML20044H065 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/28/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20044H066 | List: |
| References | |
| EA-93-057, EA-93-57, NUDOCS 9306070334 | |
| Download: ML20044H065 (6) | |
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50-498 and 50-499 License Nos.
NPF-76 and NPF-80 EA 93-057 Houston Lighting & Power Company ATTN:
William Cottle, Group Vice President. Nuclear Post Office Box 1700 Houston. Texas 77251 SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES -
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5325.000 (NRC INSPECTION REPORT NO. 93-05)
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This is in reference to an NRC inscection conducted March 8-12. 1993, at the South Texas Project (STP) Electric Generating Station.
This inspection was conducted to review the circumstances surrouncing: 1) equipment problems with turbine-oriven auxiliary feedwater oumos in STP Units I and 2 that culminated in a shutdown of Un1* 1 in February 1993: and 2) the disabling of a Unit 1 emergency diesel generator in Decemoer 1992.
The inspection disclosed eight apparent violations of NRC requirements associated with these events.
These violations were described in an inspection report (50-498 and 499/93-05)
issued on April 8. 1993, and were discussed with you and other HL&P representatives at an enforcement :onference in the NRC's Arlington. Texas office on April 22. 1993.
On February 4 1993. HL&P informea the NRC Operations Center in Bethesda.
Marylanc. of a Technical Soecificatiun-requirea shutdown of STP Unit I based on HL&P's inability to return the unit's turbine-oriven auxiliary feedwater (TDAFW) pump to an operable status.vithin the allowable time (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />).
The NRC dispatched an Augmenteo inspection Team (AIT) on the same date to review the circumstances leading uo to this event and to determine the causes of a history of TOAFW pump overspeed trios at the STP facility.
The AIT inspection report (Inspection Report 93-07)...nich described the results of this evaluation, was issued on March 24. 1993.
HL&P's investigation of these issues was descr1bec in Licensee E/ent Report 93-007. 1ssued on March 5, 1993.
As a result of the AIT inspection, the follow-up inspection described in Inspection Report 93-05, anu the "1 formation gained during the enforcement conference, the NRC has determineo that the STP Unit 1 TDAFW pump was effectively inoperaole from Decemoer 20. 1992. until February 4,1993 a period of 33 days.
The NRC concluoes that during this Deriod the pump would nave tripped on overspeeo if it hao received an automatic start signal.
In addition, the NRC has determineu inat a cause of this condition was an improper adjustment to the TOAFW pumo governor valve, which affected the operation of the turoine, contributinn to its tripping on overspeed when i
started from a normai stanoby condit. ion, in all. the NRC's inspection identifiea five violations of reuuirements relative to the maintenance and testing of the STP TDAFW pumos in units 1 and 2.
9306070334 930528 PDR ADOCK OSOO
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Power Company The circumstances surrounding these v1olations are described in the refarar ed inspection reports.
The violations include: 1) the Unit 1 TDAFW pump remaining in an inocerable condition for a period in excess of that permitted by the plant Technical Specifications: 2) a failure to perform adequate TDAFW pump surveillance testing to ensure that the pumps would operate when called upon to ao so (both units) in light of the recurring overspeed trips: 3) a failure to provide adequate instructions for conducting preventive maintenance on the Unit 1 TDAFW pump governor valve: 4) a failure to follow procedures regarding the positioning of a steam trap valve associated with the Unit 2 TDAFW pumo: and 5) the performance of maintenance on the Unit 2 TDAFW pump throttle valve linkage by an unauthorized incividual.
Water intrusion was determined to nave been the primary cause of the TDAFW pumos tripping on overspeec.
In the case of Unit 1, this was caused primarily by leakage cast MOV 514 and an improperly aajusted governor valve. These two causes effectively rendered the Unit 1 pump inoperable.
In the case of Unit 2. the overspeed trips were caused by an improper adjustment to a steam trap bypass valve.
Of troader significance, however, are: 1) the failure of HL&P's TDAFW pump surveillance test crogram to detect overspeed trip problems: 2) the failure of HL&P's corrective action program to capture recurring TDAFW pump trips as a problem in need of resolution; and 3).the failure of HL&P's work control processes to prevent the improper valve adjustments that permitted water intrusion, During the enforcement conference, you asserted that the surveillance testing performeo on the TDAFW uumps rias consistent with industry practice. While the normal plant surveillance testing program is sufficient to demonstrate that operability is maint eined, absent some known deficiency or problem. such testing rray not ervelope all conditions that impact operability, in this particular case, after severai start attempts, the pumps would perform their operability tests satisfactorily, only to subsequently trip on overspeed when started in their normal stanaby mooe.
It is our view that you should have recognized that the repetitive trips were indicative of a continuing problem for wnich you had not identified the root cause, in addition, as discussed during the enforcement conference, the NRC is also concerned about the violations that involved unaulnorizea adjustments to a steam trap drain valve and to the Unit 2 TDAFW pump throttle valve linkage.
The latter incident is of particular concern because the nalntenance performed by a senior reactor operator was observed by the cuty plant manager and general maintenance supervisor, and was not recognizeo as beina an unauthorized activity, The majority of these violati ns resulted in, or had the potential to result in, preventing the TDAFW pumos from performing their intended safety function, that of ooeratino automatic 2tly to orovide emergency feedwater to the plant's steam generators in the event of a loss of normal feedwater.
This condition is mace more serious by the fact. as discusseo below, that for a period of 61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br /> at least t,<o of the three emeraency atesei generators associated with Unit I were out of service at ',he same time, a situation wnich created tha potential, under certain accident concitions that neither the steam-drive n Unit 1 TDAFW pumo nor two of the three Unit 1 motor-driven AFW pumps wot,ld no c. w :.3:-
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In accordance with the
" General Statement of Policy ana Proceaure for NRC Erfarcement Actions,"
(Enforcement Policy) 10 CFR Part 2. Appendix C. the \\ iolations related to STP's TDAFW pumps are classified in the aggregate as a Severity Level 111 problem.
With regard to the events surrouncing the disaoling of emergency diesel generator (EDG) 13. HL&P informed the NRC's Operations Center on January 20, 1993. that EDG 13. one of three STP Unit 1 EDGs. ;had failed to start during a
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routine periodic surveillance test earlier on the same day.
HL&P's investigation of this event, whicn was documentea in Licensee Event Report 93-005. Issued on February 19. 1993. :eterminea the failure of the EDG to start to have been causea by pair,t drioping into fuei metering rod ports. The painting of the ECG began on Decemoer 29. 1992, and was completed on December 31. 1992.
Thus, the EDG appears to have been inoperaole from the date painting began until January 22. 1993, when it was restored to operability, a period of 24 days.
STP Technical Specifications permit one diesel to remain inoperaole for only 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before action must be taken to shut down the facility.
As a result of the NRC's inspection of the circumstances surrounding this I
event, and the information gained during the enforcement conference, the NRC has determined that three violations of requirements occurred.
The circumstances surrounding these violations are described in more detail in Inspection Reoort 93-05.
The violations include: 1) EDG 13 remaining in an inoperaole condition for a period in excess of that permitted by the plant Technical Specifications; 2) a f ailure to ensure that ma1ntenance activities that could affect safety-related eauipment were carried out in accordance with procedures approortate to the circumstances resulting in a failure to test EDG 13 following painting to ensure its operacility; and 3) EDGs 13 and 12 remaining in an inoperable condition for a period of 61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />, when the Technical Specifications permit sucn a condition to exist for only two hours..
The NRC notes that the second violation has been revised from that which was described in the inspection report the NRC agrees with HL&P's stated position at the enforcement conference that Procedure OPGP03-ZA-0090 was not violated in this instance.
Paint dripping into fuel metering rod ports was the obvious cause of the EDG 13 failure.
However. other factors contributeo to this failure.
First, HL&P failea to take aavantage of industry experience and information relative to diesel failures.
In NRC Information Notice 91-46. for example, the NRC described several incidents that nad resultec in render 1ng EDGs inoperable.
Three of the incidents involved painting of fuel injection assemolies, one of which (Palo Verce) aopears to have ceen identical to that which HL&P experienced.
Secondly, desp1te this and other industry information available aescribing suen incidents. HL&P failed to conouct a test of EDG 13 following painting to ensure that it had not ::een adversely af fected.
This occurrea despite the fact that a post-maintenance test was included in the original maintenance plan (it was deleted by a shift suoervisor who mistakenly believed that several operational tests of the diesel would have to be conducted and FE;M t-?f0-?:"?
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Power Company aho apparently felt that the necessary controls had been established to prevent the inadvertent disabling of the EDG).
Finally, poor communications and poor work control processes appear to have played a role in this event.
For examole, had the shift supervisor been involved in the maintenance planning discussions and understooo thatlonly one operability test was planned and the reasons for that operability test, it is unlikely that he would have eliminateo the test.
These violations resulted in an important piece of safety equipment being incapable of performing its intenoeo safety function.
In addition, based on HL&P not being aware of the condition of EDG 13, a second Unit 1 EDG was taken out of service for maintenance for ome 61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />. 5E hours of which it was actually incaoable of operating.
As indicated above, this period coincided alth the inoperable Unit 1 TDAFW pumo. significantly reducing the safety
-'argin associated with the design assumotions relative to the auxiliary feedwater system.
Therefore, in accordance with the " General Statement of Policy and Proceoure for NRC Enforcement; Actions." (Enforcement Policy) 10 CFR Part 2. Appendix C. the violations related to STP Unit l's EDGs are classified in the aggregate as a Severity level Ill;proolem.
The staff recognizes that immediate corrective action was taken when these problems were identified to restore compliance with all Technical Specification requirements, and that considerable corrective action has been taken to improve the reliability of the TDAFW pumps, to enhance TDAFW pump surveillance testing, and to prevent problems similar to that which resulted in CDG 13 being inocerable.
However, at the time of the enforcement conference. HL&P had not developed with specificity the broader corrective actions neeced to elim1nate the contributing causes of these problems, wnich included poor work control processes, poor communications, ineffective use of industry experience and information, and,the failure of the corrective action program to capture repetitive equipment problems.
To emphasize the importance of ensuring the operability of safety equipment through proper maintenance, adequate testing ano the correction of recurring problems. I have been authorized to issue the enclosed Notice of Violation and
Proposeo Imposition of Civil Penalties (Notice) in the amount of $3?S,000 for
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the two Severity Level III croblems describeo above and in the Notice.
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base value of a civil penalty for a Severity level 111 problem is $50.000.
l However, both penalties were increaseo b'ased on the following.
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l The civil cenalty adjustment factors '.n Section VI.B.2 of the Enforcement
?olicy were :onsidered ano resulteo in the following adjustments: 1) for the Severity uvel 111 oroblem related u ST;P's TDAFW pumps, the penalty was increasec 50 percent baseo on the NRC's ildentification of the inadequacies in iL&P's surveillance test program. ;C0 percent for the multiple opportunities
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j that HL&P hao to toentify ano correct the cause of TDAFW pump overspeed trips, ano 100 percent for the duration cf the anoperable Unit 1 TDAFW pump.
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'esulting in a total penalty of $175.000; ano 2) for the Severity Level !!I croblem related tu the EDGs. the penaity,was increased 100 percent based on the specific notice given with regaru to EDG problems caused by painting, and i
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100 percent for the duration of the inoperable EDG 13, resulting in a total penalty of $150.000.
The remaining adjus,tment factors in the Enforcement
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Policy were considered and no further adjustments to the civil penalties were considered approoriate.
l HL&P is requireo to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing its response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. :In oarticular, the NRC requests that HL&P aodress the actions it is taking or' plans to take to improve work control i
processes, eliminate communicottons problems, improve its corrective action program, and use industry exoerience more ef fectively.
After reviewing 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 compliance with NRC regulatory
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requirements, in accordance with 10 CFR 2.790 of the NRC's ' Rules of Practice," a copy of this letter ano its enclosure will be placed in the NRC Public Occument Room.
The responses 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
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. Milhoan Regional Administrator Enclosure:
Notice of Violation and Proposed imposition of Civil Penaities cc w/Oncl:
Hduston Lighting A Power Comoany ATTH:
William J. Jumo. Manager Nuclear u censing P.O. Box 289 Wadsworth. Texas 77483 i
City of Austin
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Electric Utilit;. Deoartment
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ATTN:
J. C. Lanier M B Lee P.O. Box 1088 Austin. Texas ~3767 L
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City Public Service Board ATTN:
R. J. Costello/M, T. Harat
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P.O. Box 1771
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Newman & Holtzinger, P. C.
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Jack R. Newman. Esq.
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Central Power and Light Company ATTN:
D. E. WararT. M. Puckett P.O. Box 2121 Corpus Christi, Texas 78403 INP0
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Records Center 1100 Circle 75 Parkway Atlanta, Georgia 30339-3064 Mr. Joseph M. Hendrie 50 Be11 port Lane
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Bellport, New York 11713 Sureau of Radiation Control State of Texas 1101 West 49th Street Austin, Texas 78756 Judge, Matagorda County Matagoroa County Courthouse 1700 Seventh Street Bay City, Texas 77414
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Licensing Representative
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Houston Lighting & Power Company
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ATTN:
Rufus S. Scott, Associate General Counsel
P.O. Box 61867 j
Houston. Texas 7?08 l
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