ML20011F192

Responds to NRC 900123 Ltr Re Violations Noted in Insp Repts 50-498/89-47 & 50-499/89-47.Corrective Actions:Heat Trace Circuit Temp Controllers Calibr & Analog Indication Checked & Found within Tolerance on All But Three Channels

ML20011F192
Person / Time
Site:	South Texas
Issue date:	02/22/1990
From:	Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ST-HL-AE-3381, NUDOCS 9003020048
Download: ML20011F192 (5)

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? The Light  ;

compting Houston Lig & PoweranySouth Teams Project Electric P.O. Boa Generating 289 Wadsworth Texas 77483 Sta .

February 22, 1990 I ST-llL AE-3381 -

File No.: G02.04 10CFR50 i U. S. Nuclear ReSulatory Commission Attention: Document Control Desk Vashington, DC 20555 -

South Texas Project Electric Generating Station Units 1 & 2 I

Docket Nos. STN 50 498, STN 50 499 Response to Notice of Violation 8947-01 Failure to Establish a Calibration Procedure for Heat Traec Control Circuits llouston Lighting & Power Company has reviewed the Notice of Violation issued as-a result of NRC Inspection Report 89 47 dated January 23, 1990 and submits the attached response. '

If you should have any questions on this matter, please contact Mr. C. A. Ayala at (512) 972-8628 or myself at (512) 972 8687.

CE.by i G. E. VaughnDO Vice President s Nucicar Operations AKK/n1

Attachment:

Reply to Notice of Violation 8947 01 i

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A Subsidiary of Houston Industries incorporated 9003020048 900222 h ,

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..: Houston Lighting & Power Company File No. : C02.04 -

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- South Texas Project Electric Generating Station r- i l- cc: '

Regiona1' Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel  ;

611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company l

' Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager U.'S. Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center  !

1100 circle 75 Parkway J. 1. Tapia Atlanta, CA 30339 3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. llendrie l

~ Commission 50 Be11 port Lane F P. : O. Box 910 Bellport, NY 11713 Bay City, TX 77414- .;

D. K. Lacker  ;

'J. R. Newman, Esquire Bureau of Radiation Control' i Newman & I:oltzinger, P.C. Texas Department of Ilealth F 1615 L Street, N.W. 1100 West 49th Street y Washington, DC 20036: Austin, TX 78704

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D. E. Ward /R. P. Verret-Central Power & Light Company P. O.-Box 2121 *

[ Corpus Christi, TX_ 78403 I

J. C. Lanier '

Director of Generation City of Austin Electric Utility >

721 Barton Springs Road i Austin, TX :78704 R. J. Costello/M. T. Hardt i- City Public Service Board i P. O. Box 1771 San Antonio, TX 78296

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i Revised 12/15/89 L4/NRC/

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South Texas Project Electric Generating Station .

Units 1 & 2 '

L Docket Nos. STN 50-498, STN 50 499 i Response to Notice of Violation 8947 01 Failure to Establish a Calibration L Procedure for Heat Trace Control Circuits fi  !

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f I. Statement of Violation TS 6.8.1 requires written procedures to be established, implemented,  ;

and maintained covering certain activities, including the applicable l procedures recommended in Appendix A of Regulatory Guide 1.33, L " Quality Assurance Program Requirements (Operation)," Revision 2, I which includes procedures for control of measuring and test equipment i and for surveillance tests, procedures, and calibrations. j Contrary to the above, as of December 21, 1989, no written procedures were established to verify the calibration accuracy of heat trace control circuits needed to accomplish TS Surveillance Requirements  ;

4.1.2.1.a and 4.1.2.2.a regarding minimum temperatures for boric acid i flow paths.

This is a Severity Level IV violation. (Supplement 1) (498/8947 01; i 499/8947 01).

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If. Houston Lichtine & Power Co. Position HL&P concurs that the violation occurred as stated.

III. Reason for Violation It was determined that the controllers and temperature monitoring modules for the Freeze Protection (NK) System were not included in the ,

procedure, OPGP03 ZM 0016. Rev. 2,.which governs the performance of ,

instrument calibrations by the Preventive Maintenance program. The specific modules in question are the Heat Trace Panels, which are used-to verify that the temperature of the boric acid system required by .

Technical Specification remains above the 65 degree temperature limit.

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Page 2 of 3 j III. Reason for Violation Cont'd. 3 p The original scope of the procedure (OPGP03.ZM 0016) was to address

!: the. calibration regairements for analog display monitoring instruments. The modules (panels) in the NK system provide both .

analog display and bistable indication. Plant Operations uses the t bistable (1smp) indication as the primary indication to ensure Technical Specification compliance. Because the original scope of the

• procedure did p_ga include calibration requirements for bistable  ;

display monitoring instruments, the modules were not included in the i original procedure.

A subsequent revision expanded the scope of the procedure to include bistable channels. During a review of surveillance procedures to determine instrumentation to be added to the OPGP03 ZM-0016 procedure, Plant Operations provided marked up copies of operator log sheets to the Maintenance I&C division (which is responsible for the procedure).

These sheets. identified the NK system modules as items to be included in the revision of OPGP03.ZM 0016. The log sheets indicate the channel numbers that Plant Operations uses to document Technical Specification compliance, rather than the instrument numbers, therefore, it was not readily apparent that these modules should be incorporated in the OPGP03 ZM 0016 procedure. Therefore, these NK channels were overlooked and not incorporated into the instrument calibration procedure.

IV. Corrective Action Taken and Results Achieved

1. The heat trace circuit temperature controllers, which give bistable indication, were calibrated. No primary circuits were found to have a controlling setpoint which wc,uld have allowed the Boric Acid line temperatures to violate the Technical Specification limits.

2. The heat trace circuit temperature analog indication was checked and'found to be within tolerance on all but three channels, which had outstanding work documents. No non-conservative displays were found. The maximum error was a reading 5 degrees below actual i (i.e., in the conservative direction).

3. A review of the previous submittal by Plant Operations of channels to be incorporated in the OPGP03.ZM 0016 revision indicated no further omissions of a similar nature.

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,' ST.HL AE 3381 F Attachment l Page 3 of 3 L-V. Corrective Actions Taken to Prevent Recurrence

1. The calibration requirements for the heat trace circuits have been included in the in process revision to OPGP03 ZM 0016.

2. HL&P will review instruments which are used to satisfy Technical

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Specification Surveillance procedures to ensure they are calibrated as necessary. This action will be completed by 3/30/90.- An evaluation of this review will determine any changes l

to the in process revision to OPGP03 ZM 0016. Any il procedure / program changes necessary will be completed by 4/16/90.

r VI. Date of Full Comoliance HL&P will be in full compliance by 4/16/90.

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