IR 05000498/1996004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/96-04 & 50-499/96-04.Review of Implementation of Corrective Actions During Future Insps

ML20135A224
Person / Time
Site:	South Texas
Issue date:	11/27/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 9612030123
Download: ML20135A224 (5)

Text

~. - - -. - . .. - ~ . ~ ... -. ~ , . . . . - ~ ~ - . - .-,~, , . ..

.

.

_

i UNIT ED ST ATES '

f(p" "'% ,I NUCLEAR REGULATORY COMMISSION 3. 3' W . $, REGloN IV l;

%. .f 611 RYAN PLAZA DRIVE. SulTE 400

%, ' "#

/ AR LINGToN, TE XAS 76011-8064

NOV 2 71996 William T. Cottle, Group Vice  ;

President, Nuclear Houston Lighting & Power Company i P.O. Box 289 '

Wadsworth, Texas 77483 I

SUBJECT: NRC INSPECTION REPORT 50-498/96-04: 50-499/96-04  !

Thank you for your letter of August 29,1996,in response to our letter and Notice

'

of Violation dated July 30,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, I

f I'

J. E. Dyer, Director Division of Reactor Projects

'

Docket Nos.: 50-498 50-499 License Nos.: NPF-76 NPF-80 cc w/ enclosure:

Lawrence E. Martin, General Manager Nuclear Assurance & Licensing Houston Lighting & Power Company P.O. Box 289

. Wadsworth, Texas 77483 Mr. J. C. Lanier/Mr. M. B. Lee City of Austin Electric Utility Department i 721 Barton Springs Road

! Austin, Texas 78704 I

9612030123 961127 PDR ADOCK 05000498 G PDR m

. ._.

.

,

Houston Lighting & Power Company -2-Mr. K. J. Fiedler/Mr. M. T. Hardt City Public Service Board P.O. Box 1771 San Antonio, Texas 78296 Jack R. Newman, Es Morgan, Lewis & Bockius 1800 M. Street, Washington, D.C. 20036-5869 Mr. G. E. Vaughn/Mr. C. A. Johnson Central Power & Light Company P.O. Box 289 Mail Code: N5012 Wadsworth, Texas 77483 INPO Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957 Dr. Bertram Wolfe 15453 Via Vaquero Monte Sereno, California 95030 Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, Texas 78756 Andy Barrett, Director Environmental Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414

. . _ .

-

.

,

Houston Lighting & Power Company -3-l

!

Licensing Representative Houston Lighting & Power Company  ;

Suite 610 Three Metro Center Bethesda, Maryland 20814 Rufus S. Scott, Associate General Counsel Houston Lighting & Power Company P.O. Box 61867 Houston, Texas 77208

. . . ..

Joseph R. Egan, Es Egan & Associates. N Street, Washington, D.C. 20037 Mr. J. W. Beck Little Harbor Consultants, Inc 44 Nichols Road Cohasset, MA 02025-1166 l

)

l l

l

._,. _ _ . . _ _ . . - - - _ . _ _ _ - _ . _ _ . . ~ , _ _ _ _ _ . . _ . . . _ . _ . _ . . _ - .

. ,

.

t Houston Lighting & Power Company -4-NOV 2 71996 ,

, ,

l (Lbec;to...DM8J1EO1EM l

j bec distrib. by RIV:

l l L. J. Callan Resident inspector l

l l .

DRS-PSB j

'

Branch Chief (DRP/A) MIS System Project Engineer (DRP/A) RIV File Branch Chief (DRP/TSS) R. Bachmann, OGC (MS: 15-B-18)

Leah Tremper (OC/LFDCB, MS: TWFN 9E10) l i

'

l

!

I i

!

i

!

!

!

!

l-  !

!

l I

I

,

i i

\

DOCUMENT NAME: R:\_STP\ST604AK.DPL k

'

To receive copy of document. Indicato in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy .

RIV:DRP/A , ._o C:DRP/A D:DRP f g;;l [

RAKopriva;df A O JITapia /tT[, JEDy We l l 11/,75/96 11/f/ /96 l .' 11/y /96 '

. OFFICIAL RECORD COPY I i

!

O30033 i

. , , . . . - , - g p, - .m p

-

.

Houston Lighting & Power Company -4-M 2 ~T E bec to DMB (IE01)

bec distrib. by RIV:

L. J. Callan Resident inspector DRS-PSB Branch Chief (DRP/A) MIS System Project Engineer (DRP/A) RIV File Branch Chief (DRP/TSS) R. Bachmann, OGC (MS: 15-B-18)

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

.. .. .

I I

l l

l DOCUMENT NAME: R:\_STP\ST604AK.DPL To receive copy of document, indicate in box: "C" = Copy weout enclosures "E" = Copy with enclosures "N" = No copy RIV:DRP/A ,

., C:DRP/A l D:DRPg l RAKopriva;df @ JITapia Q JEDy P fr 11/25/96 11/.f/ /96 l' 11/gy /96 *

OFFICIAL RECORD COPY

. .

l

. .

,

.

The Light '

c o mp a nykuth Texas Projed Dedric &nerating station P. O. Box 289 Whodh, Texas 77483 llouston Lighting & Power

. . . . 1_ --

'

August 29, 1996 l U' ST-HI AE-5451 l

'

File No.: G02.04.02 l SEPI0 U 10CFR2.201

!

U. S. Nuclear Regulatory Commission l

~~

Attention: Document Control Desk -- - ~

Washington, DC 20555 South Texas Project Unit 1 I Dock $t No. STN 50-498 l Replies to Notices of Violation 96004-01 and -04 l l

l South Texas Project has reviewed Notices of Violation 96004-01 and 96004-04, dated July 30,1996, and submits the attached replies. It should be noted that information pertaining l to the first violation was submitted to the NRC as Unit 1 Licensee Event Report 96-003, dated i July 17,1996. The events described in the Notices of Violation did not have an adverse effect on the health and safety of the publi If there are any questions regarding these replies, please contact Mr. S. M. Head at (512)

972-7136 or me at (512) 972-780 ML G. L. Parkey Plant Manager, Unit 1 DBS/dbs Attachments: 1. Reply to Notice of Violation 96004-01 2. Reply to Notice of Violation 96004-04 I

94-(956 Projecit Manager on Behalf of the Participants in the south Texas Project NRC-APWOV4M41-4 WPW

\ 9&b90 sears nt __

, ,

. .

.

. .

Houston Lighting & Power Company ST-HL-AE-5451 South Texas Project Electric Ger.erating Station File No.: G02.04.02 Page 2 Izonard J. Callan Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway i Washington, DC 20555-0001 Atlanta, GA . 30339-5957 j

David P. Loveless Dr. Bertran Wolfe Sr. Resident Inspector 15453 Via Vaquero c/o U. S. Nuclear Regulatory Com Monte Semno, CA 95030 P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bumau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Iewis & Bockius 1100 West 49th Stmet 1800 M Street, Austin, TX 78756-3189 Washington, DC 20036-5869 U. S. Nuclear Regulatory Com j M. T. Hardt/W. C. Gunst Attn: Document Control Desk City Public Service Washington, DC 20555-0001 P. O. Box 1771 San Antonio, TX 78296 J. C. Lanier/M. B. I2e J. R. Egan, Esquire City of Austin Egan & Associates, Electric Utility Department 2300 N Street, Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 Central Power and Light Company J. W. Beck ATIN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, In P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166

!

,

.

_ . - _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _

j -

-

i

i

,

,

.

g

! .

i l Attaclunent 1 j ST-HL-AE-5451 j Page 1 of 2 s

l Reply to Notice of Violation 96004-01

Stateent of Violation:

~

Technical Specification 6.8.1.a requires, in part, that written procedures be established,

! implemented, and maintained concerning the applicable procedures recommended in

'

!

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide ' - l'

1.33, Appendix A, recommends, in part, that procedures should be written covering

- surveillance tests. This requirement is implemented, in part, via the following licensee procedure:

The South Texas Project Electric Generating Station Plant Surveillance Procedure OPSP03-XC 0002, Pavison 9 "Cantainnent Inspection," was establishM to implement Technical Specifica. ion 4.5.2.c.2. ' Itis specification requires that plant personnel verify the operability of t'ae containnent emergency core cooling system sum By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containnent which could be transported to the containnent sump and cause restriction of pump suctions during LOCA condition This visual inspection is required in the areas affected within containnent at the completion of each containnent entry when containnent integrity is establishe Contrary to the above, the licensee failed to maintain Procedure OPSP03-XC-0002, ha-- on May 15,1996, a visual iama~ tion of areas affected by a containnent entry was conduct ~t in accordance with the procedure and failed to verify that no loose debris was present in cantainnent, in that, plastic bags covering equipment staged during the entry were present in containnent, could have been transported to the containnent sump, and could have canani restriction of pump suctions. ' Ibis condition existed from 3:50 p.m. on May 15,1996, until the material was removed and a containnent seinspection was completed at 5:13 a.m. on May 16,199 This is a Level IV violation (Supplement I) (498/96004-01).

IL South Texas Proiect Position:

~

. South Texas Project concurs that the violation occurre mcmmmm

. .

• ' l O

l

... , ,

l

.

..

Attachment 1 ST-HL-AE-5451 Page 2 of 2 II Reason for the Violation:

The event is described in detail, includir.g the causes, in Unit 1 Licensee Event Report ;96-003, dated July 17,199 !

'

I Conective Actions: ' :. . . .

The conective actions are outlined in Unit 1 Iicensee Event Report 964)03, dated July 17,199 ;.

i Date of Full Comoliance:

South Texas Project is in full complianc .

Or

.

MRC#980V4mM04-14WPW

.. -. _ - - - - . - - .

_- -- . - _ . -

.__7_.--

. ,

,

. .

4e ~

i i

!

Attachment 2

! ST-HL-AE-5451

. Page 1 of 3 l

.

Reply to Notice of Violation 96004-04 i

i

'

L Statement of Violation:

!

Technical Specification 6.8.1.a requires, in part, that written prucedurs be established, _

i implemented, and maintained concerning the applicable pucedu,w recommended in

! Appendix A of Regulatory Guide 133, Revision 2, huery 1978. Regulatory Guide i

1.33, Appaadit A, recommends, in part, that procedures should be written covering general plant operations involving preparation for refueling. This requirement is i implemented, in part, via the following licensee procedure:

l The South Texas Project Electric Generating Station Plant Operating Procedure OPOP03-

! ZG-0009, Revision 12, "Mid-Loop Operation," Step 4.37, requires that the two narrow

! range hot leg water level instruments, including associated remote indications, sightgla==a=

l and alarms be available during reactor coolant system drain down to the midloop levet

Contrary to the above, on May 21,1996, plant personnel failed to implement Procedure  !

! OPOP03-ZG-0009, in that, the two narrow range hot leg water level instruments, Level Transmitters LT-3660 and LT-3661, were isolated and unavailable during the reactor i coolant system drain down to the midloop.

i ~'

This is a level IV violation (Supplement I) (498/96004-04). 4

'

i l

IL South Texas Proiect Position:

i South Texas Project concurs that the violation occurred.

!

HL Reason for the Violation:

I The reason for the violation was ia=Aamiata procedural guidance.

i

, The narrow range hot leg level transmitters were calibrated on May 20,1996, in l p-@nion for mi$ loop activities. The preventative maintenance document that was used i for the calibration contains the following with regards to restoration of the transmitter:

L s'

1 PSCAMNOV4mp404-14WFW .

<

l

__ . _ . , _ _._ _ .-

. .

. .

.

~

. .

.

Attachment 2 ST-HL-AE-5451 Page 2 of 3

.. . .. .. ,

Coordinate with Operations for the restoration of transmitter to servic A joint conclusion should be reached as to whether transmitter should be placed in service or valved out until mid-loop is' reached, depending on plant conditio Due to the fact that the Reactor Coolant System was still pressurized, it was decided to l

'

maintain the narrow range bot' leg level transmitters isolated. It was anticipated at this '

time that the instruments would be unisolated just prior to draindown to mid-loo Station procedure OPOP03-ZG4)09 contains the following note in the " Notes and- l Precautions" section:

l The two narrow range hot leg (Loops 1 and 3) water level instruments including ==Ma*I remote indications, sightglasses and alarms shall be available for draindown to Mid-Loop leve However, there was no procedure step directing the transmitters be placed in servic .. . I Corrective Actions:

OPOP03-ZG-0009 was revised to include an action step requiring I&C to place the narrow range hot leg level instruments in servic An evaluation of the interface between Operations and I&C regarding configuration control ofinstrumentation was conducted to ensure there are no associated generic issue This evaluation revealed no other similar occurrences. Hence, this event is considered an isolated cas Date of Full Comoliance:

South Texas Project is in full compliance, memamemum

.. . .

. .

. .. ..

, -

Attachment 2

'

ST-HI-AE-5451 Page 3 of 3 VI. Additional Information During the time that draindown to mid-loop was in progress, redundant indications of Reactor Coolant System inventory were available. These included the two trains of Reactor Vess:1 Water level indication, the Reactor Coolant System level sightglass, and the loops 1 and 3 Reactor Coolant System level gauges. Throughout the draindown process, personnel were stationed in the Reactor Containnent Building, in direct communication with the control room, to monitor the Reactor, Coolant System level sightglass, and the loops 1 and 3 Reactor Coolant System level gauges. Frequent comparisons were made between available water level instruments to ensure that water levelindications were consisten Other indirect indications of Reactor Coolant System level were also available.- These included Residual Heat Removal pump discharge pressure, pump flow, and pump amperage. Additionally, an extra Reactor Operator, with no other concurrent duties, was stationed at the Residual Heat Removal System controls in the control roo .