IR 05000498/1997002

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/97-02 & 50-499/97-02 Issued on 970428.Corrective Actions Will Be Examined During Future Inspection

ML20140G201
Person / Time
Site:	South Texas
Issue date:	06/10/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
50-498-97-02, 50-498-97-2, 50-499-97-02, 50-499-97-2, NUDOCS 9706160052
Download: ML20140G201 (5)

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UNITED STATES

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• . NUCLEAR REGULATORY COMMISSION

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's 8 611 RYAN PLAZA oRivE, SulTE 400 AR LINGToN, TEXAS 760114064

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JUN I O 1997 William T. Cottle, Group Vice President, Nuclear Houston Lighting & Power Company P.O. Box 289 Wadsworth, Texas 77483 .

SUBJECT: NRC INSPECTION REPORT 50-498/97-02.; 50/499/97 02 Thank you for your letter of May 28,1997, in response to our letter and Notice of Violation dated April 28,1907. 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

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R T omas P. Gwy , Di ect r Division of Reac or oje s 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 l City of Austin Electric Utility Department 721 Barton Springs Road Austin, Texas 78704

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9706160052 970610 PDR ADOCK 05000498 a PDR

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I 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 i

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Jack R. Newman, Es Morgan, Lewis & Bockius .

1800 M. Street, N.W.

Washington, D.C. 20036-5869

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! Mr. G. E. Vaughn/Mr. C. A. Johnson l Central Power & Light Company l P.O. Box 289 Mail Code: N5012 Wadsworth, Texas 77483 INPO Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957 Dr. Bertram Wolfe

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15453 Via Vaquero l Monte Sereno, California 95030

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l Bureau of Radiation Control State of Texas 1100 West 49th Street l Austin, Texas 78756 Mr. Glenn W. Dishong Texas Public Utility Commission 7800 Shoal Creek Blvd.

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Austin, Texas 78757-1024 Andy Barrett, Director Environmental Policy ]

Office of the Governor P.O. Box 12428 Austin, Texas 78711

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I Fouston Lighting & Power Company -3-Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 Licensing Representative

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Houston Lighting & Power Company .

l Suite 610 l Three Metro Center Bethesda, Maryland 20814 Rufus S. Scott, Associate General Counsel l Houston Lighting & Power Company )

l P.O. Box 61867  ;

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Branch Chief (DRP/TSS) R. Bachmann, OGC (MS: 15-B-18)

DOCUMENT NAME: R:\_STP\ST702AK.DPL l To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy l RIV:DRP/A , ,, C:DRP/A J., D:DRP lM l RAKopriva;df /pA JITapia Q1_)TPGwynn y [

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company South Texas Project Electric Generating Station P.o. Ih 289 Wadsworth. Texas 77483

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Houston Lighting & Power May 28,1997 ST-HL-AE-5664 File No.: G02.04 02 10CFR2.201 l STI-30294710 l

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U. S. Nuclear Regulatory Commission l

Attention: Document Control Desk l

Washington, DC 20555 South Texas Project  ;

Unit 2  :

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Docket No. STN 50-499 Reniv to Notice of Violation 97002-01 i

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South Texas Project has reviewed Notice of Violation 97002-01, dated April 28,1997, and submits the attached reply. The events described in the Notice of Violation did not have an adverse effect on the health and safety of the public. In your cover letter that accompanied the l Notice of Violation, you requested that we also include a discussion of why corrective actions taken following the February 24,1997, event were ineffective in ensurirg tha't the material identified on March 27 was removed from the containment building. We have addressed this matter in our respons l If there are any questions regarding these replies, please contact Mr. S. M. Head at (512) '

972-7136 or me at (512) 972-798 p R. E. Masse Plant Manager, Unit 2

TCK/tek Attachment: Reply to Notice of Violation 97002-01 T ~l2 0 l

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I 9 j Ilouston Lighting & Power Company ST-HL-AE-5664 South Texas Project Electric Generating Station File No.: G02.04.02 Page 2 Ellis W. Merschoff Rufus S. Scott Regional Administrator, Region I 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

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l Thomas W. Alexion Institute of Nuclear Power l Project Manager, Mail Code 13H3 Operations - Records Center l U. S. Nuclear Regulatory Commission 700 Galleria Parkway l Washington, DC 20555-0001 Atlanta, GA 30339-5957 David P. Loveless Dr. Bertram Wolfe Sr. Resident Inspector 15453 Via Vaquero c/o U. S. Nuclear Regulatory Com Monte Sereno, CA 95030 P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, Austin, TX 78756-3189 Washington, DC 20036-5869 J. R. Egan, Esquire M. T. Hardt/W. C. Gunst Egan & Associates, City Public Service 2300 N Street, P. O. Box 1771 Washington, D.C. 20037 San Antonio, TX 78296 J. C. Lanicr/M. B. Lee U. S. Nuclear Regulatory Commission City of Austin Attention: Document Control Desk Electric Utility Department Washington, D.C. 20555-0001 721 Barton Springs Road Austin, TX 78704 l Central Power and Light Company ATTN: G. E. Vaughn/C. A. Johnson  !

P. O. Box 289, Mail Code: N5012 j

Wadsworth, TX 77483 i

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Attachment 1 ST-IIL-AE-5664 Page 1 of 4 Statement 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 1.33, Appendix A, Section 8.b.(l)(j), states that procedures should be written covering' Technical Specification surveillance tests for the Emergency Core Cooling System. This requirement is implemented, in l part, by Plant Surveillance Procedure OPSP03-XC-0002, Revision 12, " Containment Inspection," ,

that was established to implement Technical Specification 4.5.2.c.2. This specification requires

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that plant personnel verify the operability of the Containment Emergency Core Cooling System sump by a visual inspection which verifies that no loose debris (rags, trash, clcthing, etc.) is present in the containment which could be transported to containment sump and cause restrictions of pump suctions during LOCA conditions. This visual inspection is required in the )

areas affected within containment at the completion of each containment entry when containment integrity is establishe Contrary to the above, on February 23,1997, the licensee failed to verify the operability of the Emergency Core Cooling System sump when a visual inspection of areas affected by a l containment entry was conducted in accordance v.ith Procedure OPSP03-XC-0002 and failed to verify that no loose debris was present in containment. Specifically, plastic bags containing protective clothing and other loose debris that could have been transported to the containment sump and could have caused restriction of pump suctions remained in containment after the visual inspectio This is a Level IV violation (Supplement I) (499/97002-01).

I South Texas Project Position: j l

South Texas Project concurs that the violation occurre II Reason for the Violation:

The cause of these occurrences was a failure to communicate management's expectation j for the control of loose debris in the Reactor Containment Building during restart operations following an outage. A contributing cause of this event is the lack of a clear distinction in the surveillance procedure between the acceptance criteria for the Technical Specification .

l requirements and the station's housekeeping expectation l l

l Prior to entering Mode 4 following the Unit 2 fifth refueling outage, a containment i

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inspection was performed in accordance with plant procedure, OPSP03-XC-0002, Containment Inspection to ensure no loose debris existed that could render the containment sumps inoperabl l j While this inspection was being performed, ongoing maintemmce work continued in the Reactor

Containment Building. The individuals performing the inspection were aware of the ongoing

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maintenance activities, but thought all personnel had been informed of the impending Mode change and that all remaining material in the Reactor Containment Building was controlled by personnel in accordance with the OPSP03-XC-0002 requirement During the time prior to the entry into 'mde 4, personnel access to the Reactor Containment Building was restricted to the Auxv.ry Airlock while a surveillance test was performed on the Personnel Airlock. The next &y bags containing three sets of personnel contamination clothing, a few discarded booties and gloves, and a radiological controlled area warning sign were discovered unattended inside the Reactor Containment Building near the Auxiliary Airlock. Since none of this material was recorded as having entered the containment under OPSP03-XC-002, it was most probably left in the containment by personnel who were unaware of the OPSP03-XC-0002 requirements being in effect and who entered via the Auxiliary Airlock after the Mode chang While the presence of this debris constituted a failure of the procedure acceptance criteria for Technical Specification Surveillance Requirement 4.5.2.c, an evaluation determined that the Emergency Core Cooling System would not have been compromised during a design basis even This evaluation also determined it was highly unlikely the material found in the bags discovered near the Auxiliary Airlock could have migrated to the emergency sumps because of the tortuous path existing between the two locations and the lack of a motive force to move the material during a design basis even Based on the discovery of this material, additional inspections of the Reactor l Containment Building were performed. Some of the additional material found during these j inspections were conservatively assumed to have the potential to reach the emergency sumps during a design bases event. However, the total potential blockage area of this loose debris that could have reached the containment sump was determined to be far less than the blockage area

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assumed in the calculation for ensuring adequate Emergency Core Cooling System pump operatio I Corrective Actions: l All identified loose cebris has been removed from the Unit I and 2 Reactor l Containment Building . Plant Management has directed that all individuals on an entry team be briefed on acceptance criteria required for the control of loose debris in the Reactor

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Containment Building in Modes 1,2,3, and 4. Each team is assigned a Team Leader who is responsible for ensuring compliance with the requirements of l Technical Specifications. The Shift Supervisor or his designee conducts a formal l briefing ofindividuals on the entry team. The briefing requirements are part of the surveillsnce procedure and provide specific topics and material to be provided l

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to the entry team. The Reactor Containment Building inspection procedure was revised to include these requirements on April 17,199 l A process improvement team has been formed to conduct a comprehensive review and improve the Reactor Containment Building control ofloose debris to support both outage activities and at-power entries. The corrective actions identitied by l

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this team will be implemented prior to the start of the next refueling outage on September 13, 1997. Some of the items that will be considered to improve the process for outage activities are Supervisor / Foremen bri:fings to all entry team members two shifts prior to entry from Mode 5 into Mode 4, plant announcements l prior to entry into Mode 4, Controlled Access Monitors for Contaimnent entry for some specified time prior to entry into Mode 4, roving Reactor Containment 4 Building inspectors, and area maps or checklists to ensure each area is inspected. I Prior to the implementation of the process improvement team recommendations, any Reactor Containment Building entry in Mode 5 will require either each 1 individual on an entry team to be briefed on acceptance criteria required for the )

! control ofloose debris in the Reactor Containment Building in Modes 1,2,3, and 4, or other methods to ensure management's expectations are me l The procedure used to control loose debris in containment will be evaluated to ensure the acceptance criteria for Technical Specification surveillance requirements and housekeeping expectations are clearly distinguished. This will be completed by September 13,199 Date of Full Compliance:

The South Texas Project is in full complianc ADDITIONAL INFORMATION Approximately one month after the initial event, during a containment walkdown following a reactor trip, material that by the surveillance procedure acceptance criteria was classified as loose debris, was discovered in the reactor containment building. Two pieces of pipe insulation along with a small quantity ofitems such as pens and tape measures were found unsecured inside the regenerative heat exchanger room. Since this room is secured by a locked radiation protection door at-power, the two pieces of pipe insulation were not capable of reaching the containment sump.

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, Attachment 1 ST-HL-AE-5664 Page 4 of 4 The pipe insulation and the other small pieces of material should have been identified during the containment walkdowns that were part of the corrective actions for the initial event that occurred at the end of the refueling outage. This failure is attributed to inadequate communications between the personnel performing the inspection. The individual who performed the inspection did not cater the regenerative heat exchanger room based on the mistak.en belief the room had already been inspected. This failure resulted in the material not being iden;ified for removal prior to the Mode change. This issue will be addressed as a part of

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corrective action # Based on the discovery of the material in the regenerative heat exchanger room, several more inspections of both Unit I and Unit 2 Reactor Contaimnent Buildings were performe ,

Due to heightened station awareness of the loose debris issue, these additional inspections I covered areas previously not considered a concern for loose debris. These new areas included '

rooms with exits that would not allow debris to reach the cpntainment sumps and inside secured i electrical panels. In addition, this new awareness led to expansion of the definition of loose {

debris to include anything found not secured in the containment, even if it could not become an l

operability issue for the su'nps. This new inspection process identified more items that were housekeeping issues, out not of concern in the operability of the contaimnent sumps. The l corrective actions developed for the initial event are still ongoing and when completed will l provide the controls necessary to prevent this type of event in the futur I l

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