ML20035H615
| ML20035H615 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/29/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9305060086 | |
| Download: ML20035H615 (5) | |
See also: IR 05000498/1992035
Text
UNITED STATES
f[@. Q}q
NUCLEAR REGULATORY COMMISSION
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)D
REGloN IV
th.
,
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611 RYAN PLAZA DRIVE, SUITE 400
g
,
APR 291993
Docket:
50-498
50-499
License: NPF-76
NPF-80
Houston Lighting & Power Company
ATTN: William T. Cottle, Group
Vice President, Nuclear
P.O. Box 1700
Houston, Texas 77251
SUBJECT: NRC INSPECTION REPORT 50-498/92-35; 50-499/92-35 RESPONSE
Thank you for your letters of April 1 and 2,1993, in response to our letter
and Notice of Violation dated March 3,1993. We have reviewed your response
to Violation 9235-02, which cited four examples of your failure to take
appropriate corrective actions to ensure that conditions adverse to quality
are identified and that actions are taken to preclude recurrence.
In the
response, you state that you consider that the first example, although a
violation of requirements, was not a nonconforming condition.
The staff's
concern on this matter was that the foreign material in the fuel oil strainer
was considered a condition adverse to quality. A condition adverse to quality
would have necessitated your corrective action program to initiate a formal
root cause analysis.
Based on your response to Violation 9235-02, we understand that supplemental
information will be provided on the second example of Violation 9235-02 by
May 11, 1993.
Our review of your response to the third example of Violation 9235-02
determined that your root cause of the violation was inadequate.
Your
violation response identifies the cause of the Auxiliary Feedwater Pump 24
problems as being provided in Licensee Event Report (LER) 1-93-007.
Our
review of this LER indicates that the issues addressed in LER l-93-007 were
separate from the problems described in NRC Inspection Report 50-498/92-35;
50-499/92-35. This was discussed in a telephone conversation between Mr.
Wayne Harrison of your staff and Mr. Mark Satorius of this office on April 15,
1993.
Based on that conversation, we understand that additional information
concerning this example of this violation will be provided by May 11, 1993.
In your response to Violation 9235-02, you also indicate that, until full
compliance is achieved on December 15, 1993, the necessity for initiating
station problem reports to fully investigate apparent adverse trends in
equipment condition will be emphasized to station personnel.
In light of the
, poor performance that South Texas Project has exhibited in identifying and
addressing conditions adverse to quality, as evidenced by the recent escalated
/
9305060086 930429
gDR
ADOCK 05000498
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Houston Lighting & Power Company
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enforcement issues, we would expect that, in addition to emphasizing the
importance of initiating station problem reports, a more proactive and
comprehensive program to address the weaknesses identified in your corrective
action program would be developed. We understand that this topic will be
specifically addressed in the public meeting which is not yet scheduled prior
to the Unit I startup following successful completion of your auxiliary
feedwater system testing program.
After further discussions with your staff, we agree with your position that
Violation 498;499/9235-03 should be modified to restrict its application to
l
Surveillances 1/2-PSP 02-SF-0001A, -18, -lC, -2A, -2B, and -2C performed prior
to September 1991.
In addition, we have reviewed your reply to Violations 9235-05 and -06 and
find them responsive to the concerns raised in our Notice of Violation.
We
will review the implementation of your corrective actions to these two
violations during a future inspection to determine that full compliance has
been achieved and will be maintained.
Sincerely,
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0
t
&u
. Bill Beach, Director
Division of Reactor Projects
cc:
Houston Lighting & Power Company
ATTN: William J. Jump, Manager
Nuclear Licensing
P.O. Box 289
Wadsworth, Texas 77483
City of Austin
Electric Utility Department
ATTN:
J. C. Lanier/M. B. Lee
P.O. Box 1088
City Public Service Board
ATTN:
R. J. Costello/M. T. Hardt
P.O. Box 1771
San Antonio, Texas 78296
Newman & Holtzinger, P. C.
, ATTN:
Jack R. Newman, Esq.
1615 L Street, NW
Washington, D.C.
20036
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Houston Lighting & Power Company
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Central Power and Light Company
ATTN:
D. E. Ward /T. M. Puckett
P.O. Box 2121
Corpus Christi, Texas 78403
1NPO
Records Center
1100 Circle 75 Parkway
Atlanta, Georgia 30339-3064
Mr. Joseph M. Hendrie
50 Bellport Lane
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Bellport, New York 11713
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Bureau of Radiation Control
State of Texas
1101 West 49th Street
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Judge, Matagorda County
Matagorda County Courthouse
1700 Seventh Street
Bay City, Texas 77414
Licensing Representative
Houston Lighting & Power Company
Suite 610
Three Metro Center
Bethesda, Maryland 20814
Houston Lighting & Power Company
ATTN:
Rufus S. Scott, Associate
General Counsel
P.O. Box 61867
Houston,-Texas 77208
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APR 291933
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J. L. Milhoan
Resident Inspector
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Section Chief (DRP/A)
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Lisa Shea, RM/ALF, MS: MNBB 4503
MIS System
DRSS-FIPS
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Project Engineer (DRP/A)
R. Bachmann, OGC, MS: 15-B-18
Section Chief (DRP/TSS)
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P. O. Box 289 Wadsworth, Texas 77483
Houston Lighting & Power
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April 2,
1993
ST-HL-AE-4388
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File No.:
G02.04
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10CFR2.201
._ ~
U.
S. Nuclear Regulatory Commission
Attention:
Document Control Desk
20555
South Texas Project
Unit 1 and 2
Docket Nos. STN 50-498; STN 50-499
Reply to Notice of Violation 9235-02
Regarding Failure to Promptly Identify
and Correct Conditions Adverse to Ouality
Houston Lighting & Power Company (HL&P) has reviewed Notice of
Violation 9235-02 dated March 3,
1993, and submits the attached
reply.
HL&P will provide a supplemental report on this Notice of
Violation by May 11, 1993.
If you have any questions, please contact Mr.
A.
W. Harrison
at (512) 972-7298 or me at (512) 972-7921.
.
hihi
W. H. Kinse), Jr.
Vice President
Nuclear Generation
JC/pla
Attachment:
Reply to Notice of Violation 9235-02
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1R\\93-085.001
Project Manager on Behalf of the Participants in the South Texas Project
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ST-HL-AE-4388
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Houston Lighting & Power Company
File No.: G02.04
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South Texas Project Electric Generating Station
Page 2
c:
Regional Administrator, Region IV
Rufus S.
Scott
Huclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 400
Houston Lighti'.sg & Power Company
Arlington, TX
76011
P. O.
Box 61867
)
Houston, TX
77208
Project Manager
U.S. Nuclear Regulatory Commission
Institute of Nuclear Power
20555
Operations - Records Center
j
1100 Circle 75 Parkway, #1500
J.
I. Tapia
Atlanta, GA
30339-3064
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Senior Resident Inspector
c/o U.
S.
Nuclear Regulatory
Dr. Joseph M. Hendrie
Commission
50 Bellport Lane
P.
O.
Box 910
Bellport, NY
11713
Bay City, TX
77414
D.
K.
Lacker
I
J.
R. Newman, Esquire
Bureau of Radiation Control
Newman & Holtzinger,
P.C.,
STE 1000
Texas Department of Health
1615 L Street,
N.W.
1100 West 49th Street
20036
Austin, TX
78756-3189
D. E. Ward /T. M.
Puckett
U.S.
Nuclear Regulatory Comm.
Central Power and Light Company
Attn:
Document Control Desk
P.
O.
Box 2121
D.C.
20555
Corpus Christi, TX
78403
J.
C. Lanier/M.
B.
Lee
City of Austin
.
Electric Utility Department
721 Barton Springs Road
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Austin, TX
78704
K.
J. Fiedler/M. T. Hardt
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City Public Service
P.
O.
Box 1771
San Antonio, TX
78296
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Attachment 1
ST-HL-AE-4388
Page 1 of 3
REPLY TO NOTICE OF VIOLATION 9235-02
I.
Statement of Violation:
Criterion XVI to 10 CFR 50, Appendix B, requires that measures
shall be established to assure that conditions adverse to
quality,
such
as
failures,
malfunctions,
deficiencies,
deviations,
defective
material,
and
nonconformances
are
promptly identified and corrected. In the case of significant
conditions adverse to quality, the measures shall assure that
the cause of the condition is determined and corrective action
taken
to
preclude
repetition.
Procedure
OPGP03-ZX-0002,
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Revision 0, " Corrective Action Program," Section 4.1, Station
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Problem Report Instruction, requires that., "any person at
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STPEGS who identifies or becomes aware of a Condition Adverse
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to Quality (CAQ) or Significant Condition Adverse to Quality
(SCAQ) SHALL promptly document the occurrence using an SPR
Form." Four examples of violating these requirements are
stated below:
1. Contrary to the above, a station problem report was not
promptly initiated to document the foreign material (rust
like particles) found on the Emergency Diesel Generator 23
fuel oil strainers on December 4, 1992. This nonconforming
condition was identified during the performance of Service
Request DO-186915 to replace the strainers.
2. Contrary to the above, prompt corrective actions were not
initiated to correct equipment deficiencies with Essential
Chiller
21A.
Plant
Equivalency
Change
CH-178119
was
initiated in June 1992 to correct a condition which
permitted the upper oil reservoir to migrate to the lower
reservoir, requiring the essential chiller to be declared
inoperable in accordance with Technical Specification 3.7.14. On December 9,1992, the Essential Chiller 21A was
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declared inoperable because the essential chiller did not
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have sufficient indicated oil level showing in the upper
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reservoir. Plant Equivalency Change CH-178119 had not been
initiated
and
no
date
had
been
established
for
implementing the plant equivalency change.
3.
Contrary to the above,
as of December
17,
1992,
the
licensee had not identified the cause for the repetitive
problems with Auxiliary Feedwater Turbine 24 overspeed
trip mechanism and had taken no corrective actions to
preclude the recurrence of the problem.
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IR\\93-035.001
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Attachment 1
ST-HL-AE-4388
Page 2 of 3
I.
Statement of Violation: (cont'd)
4. Contrary to the above, the corrective action taken to a
violation documented in NRC Inspection Report 50-498/91-
11; 50-499/91-11 involving individuals working more than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, was not adequate to preclude
repetition. During the inspection, four individuals-were
identified to have exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> worked in a 7-day
period without plant manager approval.
One occurrence
involved an instrumentation and controls technician, with
three
additional
occurrences
involving
electrical
maintenance personnel.
These
four
examples
constitute
one
Severity
Level
IV
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violation. (Supplement I) (498;499/9235-02)
II.
Houston Lichtina & Power Position:
HL&P concurs that the cited violation occurred, but does not
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agree that the fuel oil strainer example represents a non-
conforming condition.
III.
Reason for Violation:
The
cause
for
the
second
example,
essential
chiller
modifications, is still being evaluated.
HL&P will provide a
supplemental report describing both the cause and corrective
actions by May 11, 1993.
The cause of the third example, Auxiliary Feedwatier Pump 24
overspeed trips, was reported to the NRC via LER l-93-007.
The fourth example, the adverse trend involving overtime
exceedance, was caused by a lack of training on the detailed
requirements of the Administrative Technical Specification
governing overtime. Most of the exceedances occurred because
personnel assumed that the requirement was based on a fixed
seven-day schedule instead of a rolling seven-day time period.
IV.
Corrective Actions:
The corrective actions involved with the third example,
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Auxiliary Feedwater Pump 24, have been reported to the NRC via
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LER 1-93-007.
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ST-HL-AE-4388
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Page 3 of 3
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IV.
Corrective Actions:
(cont'd)
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To
correct
the
fourth
example,
a
memo
was
issued
to
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Maintenance Department Personnel to reemphasize the STPEGS
Overtime Policy.
The Overtime Exceedance Policy (OPGP02-ZA-
,
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0060) will be replaced by OPGP03-ZA-0116 to clearly define
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management
expectations
regarding.
compliance
with
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Administrative Technical Specification requirements. . Training
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will be conducted on the new procedure.
(Completion Date:
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June 10, 1993.)
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The generic implications of this violation have also been
considered.
.The program to analyze and- trend equipment-
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history to identify repetitive component degradations and
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failures will be upgraded ' to provide for more prompt and
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effective action to prevent recurrence.
(Corrective action
will commence by April 15,
1993 and will be completed by
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December 15, 1993.)
Additionally, training-will be conducted
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to increase personnel awareness of the definition. of non-
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conforming conditions and the necessity of prompt corrective
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action.
Appropriate
plant procedures will be revised to
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include specific examples of non-conforming conditions. and
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specific instructions for dealing with non-conforming Service -
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Requests. The Service Request Form will be revised to ensure
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the
clear
indication
of
a
non-conforming
condition.
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(Completion Date: June 30, 1993).
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V.
Date of Full Compliance:
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HL&P will be in full compliance on December 15, 1993.
In the
.
interim,
the
necessity
for
initiating an
SPR to
fully
investigate apparent adverse trends in-equipment condition
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will be emphasized to station personnel.
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04/12/93
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P.O.B. zep Wad -val. T.u.a77483
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i!ouuon I.ighting & Power
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April 2,
1993
ST-HL-AE-4401
File No.:G02.04
10CFR2.201
U. S. Nuclear Regulatory Commincion
Attention:
Document Control Desk
20555
South Texas Project
Unit 1 and 2
Docket Nos. STN 50-498; STN 5-499
ReplytoNoticeofViolatioh235j
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Regarding a Failure to Fu1If T..u
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Essential Chiller ESF Loadina Timiner Sequence
Houston Lighting & Power company (IIL&P) has reviewed Notice of
Violation 9235-03 dated March
3, 1993, and submits the attached
reply.
While preparing the response to the Notice of Violation, it
became
necessary
to
contact
the
responsible
Inspector,
for
clarification.
Because of the need to contact the inspector and
the complexity of this issue, should you have objections to this
reply, I suggest that a meeting of appropriato personnel from STP
and the NRC be Convened to discuuu the issues and insure all
parties understand them.
,
If you have any questions, please contact Mr. c.
A.
Ayala at
(512) 972-8620 or me at (512) 972-7921.
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H. Ki
y, Jr.
Vice Pres dent
Nuclear Generation
RAF/pla
Attachment:
Reply-i.to1 Notice of Violation'9235-03
1R\\93-091.001
Project Manage, on Itchalf of clic Participunu ies the Suoth ^!imes Pmject
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ST-HL-AE-4401
Fila No.: G02.04
Houston Lighting & Power Company
South Texas Propct Electric Generating Station
page 2
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Regional Administrator, Region IV
Rufus S. Scott
Nuclear Regulatory Commission
Associate General Counsel
Houston Lighting & Power Company
Gil Ryan Plaza Drive, Suite 400
Arlington, TX
76011
P. O. Box 61867
Houston, TX
7/208
Project Manager
U.S. Nuclear Regulatory Commission
Institute of Nuclear Power
Operations - Records Center
Wauhington, DC
20555
'
1100 Circle 75 Parkway, #1500
Atlanta, GA
30339-3064
J.
I. Tapia
Senior Resident Inspector
c/o U.
S.
Nuclear Regulatory
Dr. Joseph M. Hendrie
Commission
50 De11 port Lane
P.
O.
Box 910
Be11 port, NY
11713
Bay City, TX
77414
D. K. Lacker
Bureau of Radiation Control
J.
R. Newman,' Esquire
Newman & Holtzinger,
P.C.,
STE 1000
Texas Department of Health
1100 West 49th Street
1615 L Street,
N.W.
20036
Austin, TX
D.
E.
Ward /T, M.
Puckett
U.S.
Nuclear Regulatory Comm.
Central Power and Light Company
Attn:
Document control Desk
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P.
O.
Box 2121
D.C.
20555
,
Corpus Christi, TX
78403
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J.
C. Lanier/M.
B.
Lee
City of Austin
Electric Utility Department
721 Barton .9prings Road
)
Austin, TX
78704
K.
J.
Fiedlcr/M.
T.
Hardt
City Public Service
P.
O.
Box 1771
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San Antonio, TX
78296
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Attachment 1
ST-HL-AE-4401
Page 1 of 4
Statement of Violation *
1.
Technical Specification 4.8.1.1.2.e.11 requires that "Each
standby diesel generator shall be demonstrated OPERABLE . . . at
nonths, during shutdown, by ... verifying
least onoo per 18
that the automatic load sequence timer is OPERABLE with the
first sequenced load verified to be loaded within 1.0 second
and all'other load blocks within +/- 10% of
and 1.6 seconds,
its design interval ..."
Surveillance Procedures 1/2-PSP 02-SF-
Contrary to the above,
0001A/1B/1C/2A/2B/2C, "ESF Diesel Sequencer 1A/1B/1C/2A/2B/2C
Timing
Test,"
did
not verify
the
entire
time
sequence
These
corresponding to the loading of the essential chillers.
procedures only verify the time sequence to the point at which
the chiller units receive a
start signal and the unit
(a fraction of the chiller
compressor oil pumps are loadedThe time delay introduced by the timers which
unit load).
were internal to the chillers wac not tested.
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This is a Severity Level IV violation.
(Supplement
I)
(498/499/9235-03)
II.
Houston Lichtinct & Power Pocition:
For Surveillances 1/2-PSP 02-SF-0001A/18/1C/2A/2B/2c performod
to September 1991, IIL&P agrees that; a violation of
prior
HL&P does
testing requirements stated in the UFSAR occurred.
not
concur
that
there
was
a
violation
of. Technical
'
Specifications in 1991 ut in 1992.
.
However, because of some confusion regarding the basis for the
It is
violation, the responsible NRC Inspector was contacted.
our understanding, after these discussions, the issue was that
the procedures are still less than adeguate in'that they d_o
not have sufficient acceptance critEfis Fo ident1ry a ra_11ure
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'aTd 3RitfEte an appropriate operability review as alsenssed in
Section 3.3.5 of Inspection Report 50-498/92-35; 50-499/92-35,
dated March 3,
1993.
IIL&P's position'is that the procedures
and the actions'taken at the time were adequate.
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The cited procedures have the following acceptance criteria
associated with the Essential Chillerc:
35 sec
K-237
Start signal - Standby Essential Chiller
K-238
Start. signal - Running Essential. Chiller
150 sec
K-239
Start signal - Running Essential Chiller
240 sec
65-70 sec
Compressor Motor Start
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ST-HL-AE-4401
Page 2 of 4
II.
Houston Liahtino Er Power Position (Continuedi:
f
internal chillor timer is verified
The acceptability of the
when both the acceptance criteria for the K-237 relay add the
This is accomplished
Compressor Motor Start are satisfied.The internal chiller timer
once in each test for all trains.
the test because it is a
-
is not testod in each sequence of
mechanical timer and is not subject to significant drift.
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Additional testing would result in undue wear on the Essential
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The combination
Chillero due to unnecessary chiller starts.
or
these
acceptance
criteria
fully
verify
the
proper
sequencing of the Essential Chillers at the times specified as
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design intervals in Table 8.3-3 of the UFSAR.
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Dackaround
In November 1991, during a review of information gathered
during' the performance of the Standby Diesel 22 LOOP-ESF
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Actuation Test and the Standby Diesel 22 LOOP Test, procedures
2 PSP 03-DG-0014
and
2 PSP 03-DG-0008
respectively,
it
was
identified that Essential Chiller 21B did not start - at
anticipated time intervals. Because these procedures were not
validate the timing of load sequencing and all
written to
other aspects of the test were satisfactory, the surveillances
However, this situation initiated a review of
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were approved.
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recently performed surveillance procedure 2 PSP 02-SF-OOOlB, ESF
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Diesel Sequencer 2B Timing Test, and discussions between the
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system engineers
for the
Standby Diesel
Generator,
Sequencer, and Chilled Water systems.
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The review of 2 PSP 02-SF-0001B indicated that the sequencer was
operating normally with the sequencer timing relays for the
Essential Chiller all functioning well within acceptance
criteria.
At this point, the system engineers. reviewed the
,
circumstances and determined that there were no operability
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questions;
based
in part,
on
the previously determined
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oversized load capacity of the diesel generators.
This
resulted in a Service Request being generated with a low
priority.
Inspection Report 92-35 states that there were inadequacies in
the procedure scope and acceptance criteria, and questioned
the' actions taken by personnel.
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Attachment 1
ST-HL-AE-4401
Page 3 of 4
II.
Houston Lichtina 6 Power Position (Continuedt:
In retrospect,
it would have been better if the system
engineers had formally documented the basis for concluding
that there were no operability concerns. .
Had this same
situation occurred under current program requirements, there
would have been no question regarding the need for a Station
Problem Report, including a documented operability review.
llovever, the engineering judgement used was sound and the
actiona taken prudent.
III.
jlyason for the violation:
Hurveillance Procedures Prior to September 1991
Why the surveillance procedures for the ESF Diesel Sequencers
did not. originally include a requirement to demonstrate proper
operation of the internal chiller timer cannot be stated with
certainty because of the length of time and personnel changes
that have occurred since the procedures were
initially
developed.
appears that the original scope of the proceduros was
It
solely the demonstration of proper operation of the sequencer.
Decause of this, the acceptance criteria were developed from
the timing requirements to initiate action to controlled
equipment instead of the design loading intervals specified in
the UFSAR.
It should be noted that for all equipment other
than the Essential Chillers these loading intervaAs are the
Either consideration did not appear to have been given
same.
to the timer internal to the Essential chiller, or the writer
believed that its operation was to be verified in other
procedures.
IV.
Corrective Action:
Survnillance Propedures Prior to Scotember 1991
Upon identification that loading times for the Essential
chillers
were
not
fully
verified
an
operability
and
reportability determination was performed.
Procedures 1/2-PSP 02-SF-0001A/1B/1C/2A/2B/2C, were changed to
incorporate additional requirements to demonstrate. proper
operation of the internal chiller timer.
This action was
completed September 27, 1991.
Tests, incorporating the new requirements, were natisfactorily
and
performed in Unit 2 during October and November of 1991;
in Un.1t i during october and November of 1992.
IR\\93 091.001
J
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13:07
5129728298
012
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Attachment 1
ST-ML-AE-4401
Page 4 of 4
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Date of Full Compliance:
V.
1991,
full compliance since September 27,
,'
The chiller
IIL&P has been in
when the survei31ance procedures were modified.
i
1991.-
timer adequacy was verified by August,
!
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iR\\93 091.001
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The Li9 t
was
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c o mp a ny S uth Texas Project Electric Generating Station
'
P. O. Box 289 Wadsworth, Texas 77483
l
Houston Lighting & Power
'
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.
April 1,
1993
,
ST-HL-AE-4378
File No.:
G02.04
10CFR2.201
\\
-
U. S. Nuclear Regulatory Commission
!
Attention:
Document Control Desk
20555
South Texas Project
Unit 1 and 2
Docket Nos. STN 50-498; STN 50-499
Reply to Notice of Violation 9235-05
l
Regarding Failure to Follow
Radiolocical Procedures and Postinas
Houston Lighting & Power Company (HL&P) has reviewed Notice of
Violation 9235-05 dated March
3,
1993, and submits the attached
reply.
If you have any questions, please contact Mr. C.
A. Ayala at
(512) 972-8628 or me at (512) 972-7921.
b.b
W. H. Kinsey, Jr.
Vice President
'
Nuclear Generation
RAD /pla
f
Attachment:
Reply to Notice of Violation 9235-05
o 'l 9{s'
a
loy-p
cx : J A * o 3
y 0975
1
-081.003
Project Manager on Behalf of the Participants in the South Texas Project
i
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.
ST-HL-AE-4378
Houston Lighting & Power Company
File No.: G02.04
i
South Texas Project Electric Generating Station
Page 2
c:
l
i
Regional Administrator, Region IV
Rufus S.
Scott
Nuclear Regulatory Commission
Associate General Counsel
l
611 Ryan Plaza Drive, Suite 400
Houston Lighting & Power company
Arlington, TX
76011
P.
O.
Box 61867
Houston, TX
77208
Project Mar.ager
,
'
U.S. Nuclear Regulatory Commission
Institute of Nuclear Power
20555
Operations - Records Center
1100 Circle 75 Parkway, #1500
J.
I.
Tapia
Atlanta, GA
30339-3064
Senior Resident Inspector
c/o U.
S.
Nuclear Regulatory
Dr. Joseph M. Hendrie
Commission
50 Bellport Lane
P.
O.
Box 910
Bellport, NY
11713
Bay City, TX
77414
D.
K.
Lacker
J.
R. Newman, Esquire
Bureau of Radiation Control
Newman & Holtzinger,
P.C.,
STE 1000
Texas Department of Health
1615 L Street,
N.W.
1100 West 49th Street
20036
Austin, TX
78756-3189
D. E. Ward /T. M.
Puckett
U.S.
Nuclear Regulatory Comm.
Central Power and Light Company
Attn:
Document Control Desk
P.
O.
Box 2121
D.C.
20555
Corpus Christi, TX
78403
J.
C. Lanier/M.
B.
Lee
City of Austin
-
Electric Utility Department
721 Barton Springs Road
Austin, TX
78704
K. J. Fiedler/M. T.
Hardt
City Public Service
P.
O.
Box 1771
San Antonio, TX
78296
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Attachment 1
ST-HL-AE-4378
Page 1 of 4
I.
Statement of Violation:
Technical Specification 6.11.1 states that procedures for
personnel radiation protection shall be prepared consistent
with the requirements of 10CFR20 and shall be approved,
maintained,
and adhered to for all operations involving
personnel radiation exposure.
Two examples of violating this
requirement are stated below:
,
1.
Procedure
OPGP03-ZR-0002,
Revision
9,
" Radiological
)
Controlled Area Access and Work Control,"
Step
5.5,
l
states, in part, that, when exiting the radiologically
restricted
area,
personnel
will
use
a
personnel
contamination monitor and, if not available, will perform
a whole-body frisk as directed by Health Physics.
Contrary to the above, on December 7,
1992, a licensee
worker exited the Unit 1 radiologically restricted area
'
without utilizing a personnel contamination monitor or-
performing a whole-body frisk.
2.
Procedure
OPRP02-ZX-0007,
Revision
5,
" Radiological
Posting and Warning Devices," Paragraph 4.2.2,
requires,
in part, that, the radiological posting signs be hung from
barriers such that the posting is clearly visible when
approaching the area.
Paragraph 4.3 establishes areas as
,
requiring radiological postings as any area where access
is
controlled
by HP
for purposes
of
protection
of
individuals from exposure to radiation and/or radioactive
materials.
Areas
outside
the
main
Units
1
and
2
radiologically controlled area (RCA) should be identified
as an RCA if the dose rates at 18 inches exceed 0.5 mr/hr.
,
Contrary
to
the
above,
on
December
4,
1992,
the
,
radiological
posting
was
not
adequate
to
restrict
personnel access from an area outside the main Units 1 and
2 RCA where dose rates exceeded 0.5 mr/hr at 18 inches.
j
During a radiation monitor calibration, while the source
l
was exposed, a licensee employee entered into the Unit 2
control room through the south door and violated the
radiological posting in place for the surveillance.
The
radiological posting sign had been hung from the door and
not from barriers such that the posting was not clearly
visible when approaching the door.
This is a Severity Level IV violation.
(Supplement I)
(498;499/9235-05)
,
IR\\93-081.003
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Attachment 1
ST-HL-AE-4378
Page 2 of 4
II.
Houston Liahtina & Power Position:
HL&P concurs that this violation occurred.
III.
Reason for Violation:
1.
The cause of this event was failure of the worker to
follow standard radiological work practices, as described
in, OPGP03-ZR-0002, Revision 9,
" Radiological Controlled
Area Access and Work Control," Step 5.5.
The individual
exited the radiological controlled area
(RCA) without
performing a whole body frisk.
Contributing to the event was that the equipment was being
loaded through the Mechanical Auxiliary Building (MAB),
331 door, which is located on a platform on the 60'
elevation, approximately 30 feet above the ground.
The
area in which the work was being performed (60' MAB and
loading platform) is a radiological " clean" area;
i.e.,
not contaminated.
The workers could not permenently exit
the RCA without traversing the MAB and exiting through the
normal RCA egress and through the personnel contamination
monitors.
In addition, a positive barrier was not established to
remind workers where the RCA boundary was located.
2.
The cause of this event was a failure of an employee to
identify and follow a radiological posting.
Contributing
to the event was that the radiation area was outside the
main Unit 1 and 2 RCA.
In addition, the posting was not
hung on a barrier other than the door used for normal
control room access. Health Physics technicians providing
job coverage for the radiation monitor calibration stopped
the individual prior to his actual entry into the Unit 2
control room.
The dose rates in the area of the door
threshold were $ 0.2 mR/hr.
IR\\93-081.003
.
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Attachment 1
ST-HL-AE-4378
Page 3 of 4
IV.
Corrective Actions:
la.
Health Physics personnel verified that the workers
involved were free of contamination.
No contamination
was found on personnel.
Ib.
The Health Physics Operations General Supervisor issued
night
orders
to
Health
Physics
personnel
which
emphasized the procedural requirement to perform a
whole-body frisk prior to exiting the RCA and provided
guidance on the transfer of material through the MAB,
331 doors.
ic.
A TechnicaA Services Training Bulletin was issued to
Health Physics personnel describing the event and
explaining
performance
expectations
for
job
coverage / work control
of
the
loading / unloading
of
material through the MAB, 331 doors.
Id.
General Employee Radiation Worker Training (GET II)
will be enhanced to provide' training on controls for
alternate access points to.the RCA, such as, the MAB
331 doors,
Reactor Containment
Building equipment
hatch, Fuel Handling Building truckbay, and radioactive
waste yards.
The enhanced training will be in effect
by June 30, 1993.
le.
A
review
of
monitoring
and
access
control
requirements will be performed.
Additionsl guidance
will be provided based on the results of the review.
i
This will be completed by November 19, 1993.
2a.
Access to the control room through the south door was
suspended by the Shift Supervisor and a radiological
barrier (magenta and yellow rope) was suspended across
the door's threshold with the posting attached to the
barrier.
Also, the card reader allowing door access
was disabled to preclude possible breaches of the
posting.
2b.
Health
Physics
personnel
initiated
Radiological
Occurrence
Report
2-92-0131
and
suspended
the
individual's RCA access pending counseling of the
individual by a Health Physics Supervisor and the
individual's Supervisor.
IR\\93-081.003
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Attachment 1
ST-HL-AE-4378
Page 4 of 4
IV.
Corrective Actions:
(con't)
2c.
The Training Bulletin described in action lc above
included a description of this event and explained
performance
expectations
for radiological postings
outside
the main Units
1
and
2
RCA boundaries,
including the construction of a positive barrier, such
as magenta and yellow rope, which is different from
normal
access
barriers.
The
Training
Bulletin
described in actions ic and 2c will be discussed at
biweekly crew meetings.
This will be completed by
April 30, 1993.
OPRP02-ZX-0007, Revision 5, " Radiological Posting and Warning
Devices," will be revised to clarify the use of positive
barriers for radiological postings outside the main Units 1
and 2 RCA and for movement of RCA boundaries to allow transfer
of material.
The procedure will be revised and effective by
May 31, 1993.
The lessons learned from these events will be discussed in
General Employee Training GET I and GET II requalification
training.
The lesson plans will be revised by June 30, 1993.
V.
Date of Full Compliance:
HL&P is in full compliance at this time..
.
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1R\\93-081.003
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The Light
c o m p a ny South Texas Project Electric Generating Station
P. O. Box 289 Wadsworth, Texas 77483
Houston Lighting & Power
,
April 2,
1993
1
32bN
ST-HL-AE-4402
'
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4
File No.:
GO2.04
^
-
r
,
10CFR2.201
'
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~- -
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'
U.
S. Nuclear Regulatory Commission
Attention:
Document Control Desk
20555
South Texas Project
Unit 1 and 2
Docket Nos. STN 50-498; STN 50-499
Reply to Notice of Violation 9236-06
Recardina Failure to Reauest Relief from ASME Reauirements
Houston Lighting & Power Company (HL&P) has reviewed Notice of
Violation 9236-06 dated March
5,
1993, and submits the attached
reply.
HL&P will provide a supplemental report on this Notice of
Violation by May 11, 1993.
If you have any questions, please contact Mr.
C. A. Ayala at
(512) 972-8628 or me at (512) 972-7921.
.
S.
Rosen
.
Vice President
Nuclear Engineering
'
GLM/ag
Attachment:
Reply to Notice of Violation 9236-06
l
1
,
W " % 93-pi0
l
IR\\93-076.001
Project Manager oti Behalf of the Participants in the South Texas Project
i
?
.
.
ST-HL-AE-4402
Houston Lighting & Power Company
Fi
1 o. : G02.04
l
South Texas Project Electric Generating Station
c:
Regional Administrator, Region IV
Rufus S. Scott
i
Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 400
Houston Lighting & Power Company
4
I
Arlington, TX
76011
P.
O.
Box 61867
Houston, TX
77208
Project Manager
U.S. Nuclear Regulatory Commission
Institute of Nuclear Power
20555
Operations - Records Center
1100 Circle 75 Parkway, #1500
J.
I. Tapia
Atlanta, GA
30339-3064
Senior Resident Inspector
c/o U.
S. Nuclear Regulatory
Dr. Joseph M. Hendrie
Commission
50 Bellport Lane
P.
O.
Box 910
Bellport, NY
11713
Bay City, TX
77414
D.
K.
Lacker
J.
R.
Newman, Esquire
Bureau of Radiation Control
Newman & Holtzinger,
P.C.,
STE 1000
Texas Department of Health
i
1615 L Street,
N.W.
1100 West 49th Street
'
l
20036
Austin, TX
78756-3189
1
D.
E. Ward /T. M.
Puckett
U.S.
Nuclear Regulatory Comm.
I
Central Power and Light company
Attn:
Document Control Desk
l
P.
O.
Box 2121
D.C.
20555
Corpus Christi, TX
78403
l
J.
C. Lanier/M.
B.
Lee
City of Austin
Electric Utility Department
721 Barton Springs Road
Austin, TX
78704
K.
J. Fiedler/M.
T.
Hardt
City Public Service
P.
O.
Box 1771
San Antonio, TX
78296
l
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Attachment 1
ST-HL-AE-4402
Page 1 of 2
-
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I.
Statement of Violation:
4
Failure to Reauest Relief from ASME Code Reauirements
10 CFR 50.55a requires that ASME Code Class 3 pumps and valves
whose function is required for safety undergo IST which complies
with the requirements of ASME Section XI to verify operational
readiness, unless relief has been granted.
i
Article IWP-4110 of ASME Section XI, requires that instruments
used in IST be of a quality such that instrument accuracy is
within 2 percent of full scale.
I
Contrary to the above, the essential cooling water flow element
installation for the Units 1 and 2 component cooling water heat
exchanger had an error of 7 percent of full scale and no relief
from the provisions of Section XI was granted.
This
is
a
Severity Level
IV violation.
(Supplement
I)
(498;499/9236-06)
II.
Houston Lichtina & Power Position:
HL&P concurs that the cited violation occurred.
III.
Reason for Violation:
The cause of the event was inadequate management controls to
ensure that request for relief from the requirements of ASME
Section XI was submitted in a timely manner.
IV.
Corrective Actions:
l
1.
An investigation was performed to determine if instrument
'
inaccuracies similar to those discovered in the Essential
Cooling Water (EW) System existed in other systems.
Similar
instrument inaccuracies were discovered in the Essential
Chilled Water (CH) and Safety Injection (SI) systems.
2.
An evaluation of the data collected during previous ASME
Section XI pump testing was conducted and concluded that the
EW, CH, and SI instrumentation provided results capable of
detecting pump degradation and therefore met the intent of
ASME Section XI. ' System operability for EW, CH, and SI was
reviewed and was determined to not be a concern due to
sufficient margin existing
between the design and
the
,
required system flow rates.
'
IR\\93-076.001
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Attachment 1
ST-HL-AE-4402
Page 2 of 2
IV.
Corrective Actions:
(con't)
3.
temporary flow measurement
devices capable of achieving the required ASME Section XI
accuracy will be used until the existing instrumentation is
precision calibrated to resolve the inaccuracies.
Use of
these devices requires revision to the reference value
procedures,
inservice test procedures,
and controlotron
calibration specification sheets for the CH and SI systems.
These revisions will be completed prior to their next
performance.
4. For the EW system, an analysis of the methodology required
to meet the ASME Section XI accuracy is continuing.
The
results of this analysis and the date of compliance with
ASME Section XI for the EW system will be provided in a
supplemental report scheduled for May 11, 1993.
5.
Procedures OPGP03-ZE-0021, " Inservice Testing Program for
Valves", and OPGP03-ZE-0022, " Inservice Testing Program for
Pumps"
will be revised to require that relief requests be
submitted to the NRC within six months of discovery of the
need for the requests.
This revision will also require that
compensatory actions be taken, as required, until the relief
request is granted by the NRC.
These procedures will be
revised by September 23, 1993.
6.
To
prevent
recurrence,
procedure
IP-3.04Q,
" Inservice
Inspection
Program",
was
revised to
require
that the
responsible engineer ensure that the instrumentation used to
collect data for inservice testing is accurate to within the
tolerances specified in ASME Section XI prior to inclusion
of the instrumentation in the testing plan.
In addition,
procedure OPGP03-ZE-0031, " Design Change Implementation",
was revised to require consideration of programmatic impact
to the ASME Section XI Pump and Valve Testing Program in the
event of a design change to the existing configuration.
Also,
the +/-
2%
instrument accuracy was specifically
identified as a potential impact to Section XI equipment on
the Design Change checklist.
V.
Date of Full Compliance:
The
and
systems
will
be
in
compliance
with
the
requirements of ASME Section XI prior to their next performance.
HL&P
will
provide
the
date
of
full
compliance
in
the
supplemental report scheduled for May 11, 1993.
IR\\93-076.001
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Houston Lighting & Power Company
-4-
ppR 29 i%
bec'to DMB (IE01)
bcc distrib. by RIV:
J. L. Milhoan
Resident Inspector
Section Chief (DRP/A)
Lisa Shea, RM/ALF, MS: MNBB 4503
MIS System
DRSS-FIPS
RIV File
Project Engineer (DRP/A)
R. Bachmann, 0GC, MS: 15-B-18
Section Chief (DRP/TSS)
040168
e