IR 05000498/1998015

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/98-15 & 50-499/98-15.Corrective Actions Reviewed & Found to Be Responsive to Issues Raised

ML20207E637
Person / Time
Site:	South Texas
Issue date:	05/28/1999
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
50-498-98-15, 50-499-98-15, EA-99-008, EA-99-117, EA-99-8, NUDOCS 9906070092
Download: ML20207E637 (6)

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To e REGloN IV 611 RYAN PLAZA drive, sulTE 400

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William T. Cottle, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 SUBJECT: NRC INSPECTION REPORT 50-498/98-15; 50-499/98-15

Dear Mr. Cottle:

Thank you for your letter of March 10,1999, in response to our February 10,1999, letter and Notice of Violation 98015-02. This violation involved the failure to meet Technical Specification 3.8.2.1 when the Unit 1 Channel 111125-volt Battery Bank E1811 was rendered inoperable and the operators failed to satisfy the associated action statement that required placing the reactor in at least hot standby within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

In your response, you did not agree that a violation occurred. You stated that Technical Specification requirements for specific gravity were satisfied before the plant was required to be in Mode 3. Your determination was based on analytic results and not actual plant data available to the operators responsible for compliance with the applicable requirements. Your letter acknowledged that a proper operability review had not been performed and that the decision making process 5 exiting the applicable Limiting Condition for Operation was flawed.

Specifically, you noted that : nur staff erroneously believed that the battery would remain operable as long as the battery terminal voltage remained above 110 volts.

After considering your submittal, the agency has confirmed that the South Texas Project Technical Specifications are explicit in addressing battery operability. Table 4.8-2, Notation (3),

specifically states that any Category B parameter, not within its allowable value, is prima facie p indication of an inoperable battery. Notation (5) of Technical Specification Table 4.8-2, related I to the Category B parameter of average specific gravity of all connected cells, indicates that the minimum allowable value for operability of Battery Bank E1811 is a battery charging current of {

less than 2 amps when on charge. IEEE Standard 450 indicates that specific gravity data is unreliable if cellected when the battery is charging. Therefore, the use of charging rate, as opposed to specific gravity measurements or calculations, whenever the battery is charging at greater than 2 amps, is the correct methodology for determining battery operability.

Although the question of individual cell voltage was raised in the inspection report, battery inoperability was not assumed until calculated specific gravity fell below the minimum value for operability in Table 4.8-2. We agree with your determination that, for the purpose of this discussion, individual cell voltage was not germane. However, it was also not material to our original enforcement decision.

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STP Nuclear Operating Company -2-Our Notice of Violation stated that Unit 1 Channel ll1125-volt Battery Bank E1811 was inoperable for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and 35 minutes, from June 14 at 8:02 p.m. until June 15 at approximately 10:37 a.m. The star 1 of inoperability correlated to your calculated time of inoperability documented in the study calculation based on Calculation EC-5998, Revision 10.

The end of inoperability correlated to the plant computer indication of the earliest time that the battery charging rate dropped below 2 amps.

Accordingly, we continue to find that a violation of NRC requirements did occur. Although capable of performing its intended safety function, Battery Bank E1811 was inoperable, according to Technical Specification requirements for battery operability, from at least June 14 at 8:02 p.m. when your calculations indicated a specific gravity less than the Technical Specification minimum value for operability until June 15 at approximately 10:37 a.m., the earliest time that battery charging rate dropped below 2 amps. This was longer than the allowed outage time in Technical Specification 3.8.2.1. Nevertheless, we have reviewed your corrective actions taken and find that they are responsive to the issues raised. Therefore, you are not required to respond further to this violation.

Should you have any questions regarding this matter, please contact me at (817) 860-8226 or Mr. Ken Brockman, of my staff, at (817) 860-8248.

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Thomas P. Gwy n Deputy Region I Adm' istr tor cc:

T. H. Cloninger, Vice President Engineering & Technical Services STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 A. Ramirez/C. M. Canady City of Austin Electric Uti!ity Department 721 Barton Springs Road Austin, Texas 78704 Mr. M. T. Hardt/Mr. W. C. Gunst City Public Service Board P.O. Box 1771 San Antonio, Texas 78296

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'STP Nuclear Operating Company -3-D. G. Tees /R. L. Balcom Houston Ughting & Power Company P.O. Box 1700 Houston, Texas 77251

'Jon C. Wood Matthews & Branscomb One Alamo Center 106 S. St. Mary's Street, Suite 700 San Antonio, Texas 78205-3692

' Jack R. N9wman, Esq.

Morgan, Lewis & Bockius 1800 M. Street, N.W.

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 Bureau of Radiation Control State of Texas '

1100 West 49th Street Austin, Texas 78756 ,

Mr. Jim Calloway Texas Public Utility Commission William B. Travis Building .

1701 North Congress Avenue P.O. Box 13326 Austin, Texas 78701-3326 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428

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Austin, Texas 78711 -

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Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414

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Nuclear Operating Company

saa rauamaractieccanswn, ra sum us,arr ranmn m March 10,1999 NOC-AE-000458 i l

File No.: G02.04.02 10CFR2.201 STI: 30825375 l

U. S. Nuclear Regulatory Commission  !

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Attention: Document Control Desk Washington,DC 20555 PW 2 31999 j South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Response to Notice of Violation 98015-02 South Texas Project has reviewed the Notice of Violation contained in Inspection Report 50-498/499 98015 dated Febmary 10,1999, and submits the attached reply. The only commitments contained in this correspondence are located in the Corrective Actions section of the attaclunent.

South Texas Project continues to believe that our performance during this event did not meet our expectations. The operability decision made regarding the ElB11 battery did not consider all necessary information, nor was there a complete understanding of battery operation. However, South Texas Project believes that the requirements of Technical Specification 3.8.2.1 were met during the event and therefore, we must respectfully deny that a violation occurred. Our position is explained in Attachment 1 of this letter. Notwithstanding our position with respect to the violation, South Texas Project understands our shortcomings during this event, and has included corrective actions in Attachment 1 for your information.

If there are any questions regarding this information, please contact Mr. W. E. Mookhoek at (512) 972-7274 or me at (512) 972-8757.

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J. J. Sheppard

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Vice President and Special Assistant to the President

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WEM Attachments: 1. Response to Notice of Violation 98015-02 m,__ , Ttec5

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File No.:G02.04.0? .

G03.17

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Ellis W. Merschoff Jon C. Wood Regional Administrator, Region IV- Matthews & Branscomb U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington, TX 76011-8064 San Antonio,TX 78205-3692 Thomas W. Alexion Institute ofNuclear Power Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway

. Washington, DC 20555-0001 Atlanta, GA 30339-5957 Cornelius F. O'Keefe - Richard A. Ratliff Sr. Resident Inspector Bureau ofRadiation Control c/o U. S. Nuclear Regulatory Commission Texas Department of Health P. O. Box 910 - 1100 West 49th Street Bay City, TX 77404-0910 Austin,TX 78756-3189 J. R. Newman, Esquire D. G. Tees /R. L Balcom Morgan, Lewis & Bockius Houston Lighting & Power Co.

1800 M. Street, N.W. P. O. Box 1700 Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service ATTN: G. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 78296 Wadsworth,TX 77483 A. Ramirez/C. M. Canady 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

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Attachment 1 NOC-AE-000458 Page 1 of 4 Reply to Notice of Violation 98015-02 1. Statement of Violation:

During a NRC inspection conducted'on June 14 through November 23,1998, one violation of ;

NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 3.8.2.1 is applicable while the reactor is in Mode 1 and states, "As a minimum, the following D.C. electrical sources shall be OPERABLE... Channel III 125-volt Battery Bank ElB11." The associated action -

statement requires, "With one of the required battery banks inoperable, restore the inoperable battery bank to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

Contrary to the above, from June 14 at 8:02 p.m. until June 15,1998, at i

approximately 10:37 a.m., a period greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, Unit 1 Channel HI 125-volt Battery Bank ElBil was inoperable with the reactor in Mode 1 and the reactor was not placed in at least hot standby within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This is a Severity Level IV violation (Supplement I).

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II. South Texas Proiect Position:

South Texas Project does not agree that a violation of Technical Specifications occurred. South Texas Project believes we were in compliance with Technical Specification 3.8.2.1 requirements during the specified period, even though a proper operability evaluation was not performed at the time.

At 1705 on June 14,1998 the Unit I control room was notified of smoke in the ESF 4.16kv Train B Switchgear. The Switchgear was deenergized at 1708. The cause of the fire was later detennined to be a failure of a potential transformer in the switchgear. The staffwas focused on the restoration of power to the ElB bus during this event and thus the restoration of a battery charger. The staff erroneously believed that the battery would remain OPERABLE as long as the tenninal voltage remained above 110 volts. As stated in the inspection report, there was a demonstrated lack of battery operation knowledge during this event. The staff believed that the battery remained OPERABLE during the entire duration of the event and did not question the status of the battery until the question of operability was raised by the NRC Resident Inspector.

Once prompted, the stafTtook action to investigate the question of battery operability even though we still believed the battery was operable. South Texas Project believes that the consideration given to battery operability was incorrect and incomplete; however, the subsequent

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{h Attachment 1 NOC-AE-000458 Page 2 of 4 Janalysis did. determine the battery to be operable before the plant was brought into Mode 3. This

. process did not meet station expectations and actions have been taken to correct the deficiencies discovered during this event.

Even though the decision making process for exiting all Limiting Conditions for Operation invoked as a result of this event was flawed, South Texas Project believes that a violation of a- Technical Specifications did not occur. The timeline that occurred during the event had the - i

' station battery recharged to a point where it satisfied the Technical Specification requirements for -

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. specific gravity, and thus battery capability, before the plant was required to be in Mode 3. 'Ihis

, occurred fortuitously and not by any speci6c actions taken by the staff. Analysis of the battery condition, performed after the event, and acknowledged by the inspection report, demonstrated that the battery could have perfonned its intended function throughout the event. The analysis

_ calculated the actual design bases capability of the battery and proved that the battery was capable of performing its two-hour post-accident duty cycle.

The position taken in Inspection Report 98015 stated that when the individual cell voltage dropped below 2.07 volts, the battery became inoperable. The battery would not be able to satisfy this requirement without a charger even though it was fully capable of performing its intended safety function. South Texas Project believes that this parameter does not relate to operability, but def'mes a point of condition for the battery where comparisons may be made from test to test, .similar to those used by Section XI testing for mechanical systems. Therefore, we

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believe that the position taken in the Inspection Report is not germane to OPERABILITY in this case. The battery vendor evaluated battery capability during this event. The result of this evaluation supports the conclusion reached by the South Texas Project.

Conclusion o

Although South Texas Project believes we were in compliance with Technical Specification 3.8.2.1 requirements during the specified period, we recognize that our performance was lacking '

during this event and have completed corrective actions to address these issues.

III. Reason for the Violation:

As noted above, South Texas Project does not believe that a violation occurred.

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IV. Corrective Actions:

The followin~g conective actions have been taken with respect to this issue: ,

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1. Additional training on battery fundamentals was developed and delivered to all appropriate personnel that included:

e the effect of partial discharge on specific gravity and battery operability l

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Attachment 1 NOC-AE-000458 Page 3 of 4

e how to interpret battery capacity based on discharge and charge current levels

.. the accuracy of specific gravity testing during charge and discharge cycles

• ' application ofTechnical Specification 3.8.2.1.

2. The supervisory oversight lessons leamed from this event were incorporated into the Conduct of Operations Manual.

3. Procedure OPOP02-EE-0001, ESF (Class 1E) DC Distribution System was revised to include information for battery operability determinations during and following discharge events.

i 4. Procedure OPOP04-DJ-0001,IAss of Class IE lE5 VDC Power was revised to include a " NOTE" delineating the limits imposed in procedure OPOP02-EE-0001.

5. Procedure OPOPO4-AE-0001, Loss of Any 13.8 kV or 4.16 kV Bus was revised to include a " CAUTION" delineating the limits imposed in procedure OPOP02-EE-0001 during partial battery discharges. The revision to OPOP04-AE-0001 also included ,

Technical Specification lessons learned from this event. )

6. Procedure OPSP06-DJ-0001,125 Volt Class IE Battery 7 Day Surveillance Test, and OPSP06-DJ-0002125 Volt Class IE Battery Quarterly Surveillance Test was revised to include clarification on the accuracy of specific gravity measurements during charge and discharge cycles and float conditions.

V. Date of Full Comoliance:

I South Texas Project continues to be in full compliance.

VI. AdditionalInformation:

The cover letter ofInspection Report 50-498; 50-499/98015 requested South Texas Project to provide a description of our corrective actions to ensure that knowledge and plant procedures are adequate to promptly restore power to safety-related equipment following a station blackout.

The corrective actions listed above address this issue as well as others identified by our review of this event. In addition to those actions listed in this attachment as corrective actions, a number of J

other enhancements are included below that will improve our processes:

= 1. All engineering personnel that perform or direct surveillance procedure performance liave been trained on the importance of surveillance procedure performance for

- operability testing. This training stressed the difference between the use of a surveillance procedure for support of a work order and for operability testing. !

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., Attachment 1 NOC-AE-000458 Page 4 of 4 2. South Texas Project has developed and will implement a modification for the safety related 480-volt load center feeder breaker handswitches on the Main Control Board to prevent tripping the breakers in similar circumstances due to activation of the " anti-pump relay". These modifications will be installed in the plant during the refueling outages scheduled for spring and fall this year.

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Ke ords for SLIVs and NCVs:

090701 Disputed Requirement 090705-No OE Interest 090709-NRC Prevall 090702-Disputed Facts 090706 48hr Review 090708 Licensee Prevall 090703 Disputed Policy; 090707-Full Review 090710-Mixed Decision 090704-Disputed SL 090303.Vil.B.1 Discretion (for NCVs

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