ML20058D387

Notice of Violation from Insp on 900912-21.Violation Noted: on 900912,Unit 1 Entered Mode 3 W/One ECCS Subsystem Inoperable & Subsystem Not Restored to Operable Status Until Temp of RCS Cold Legs Reached 385 F

ML20058D387
Person / Time
Site:	South Texas
Issue date:	11/01/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058D381	List: IR 05000498/1990031 ML20058D387
References
50-498-90-31, EA-90-164, NUDOCS 9011060082
Download: ML20058D387 (10)

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NOTICE OF VIOLATION

' Houston Lighting & Power Company Docket Nos. 50-498 and 50-499 South Texas Project, Units 1 & 2 License Nos. NPF-76 and NPF-80 EA 90-164 During an NRC inspection conducted September 12-21, 1990, a violation of NRC requirements was identified.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2. Appendix C

- (1990),=the violation is listed below:-

South Texas Project Technical Specification (T.S.) 3.0.4 states, in part, that entry into an operational mode or other specified condition shall not be made when the conditions for the Limiting Condition for Operation are not met and the associated action recuires a shutdown if they are not i-met within a specified time interval, and states that exceptions to these L

-requirements are stated in the individual specifications.

L South Texas Project T.S. 3.5.2, a Limiting Condition for Operation, states, 1

L in part, that three independent Emernency-Core Cooling System (ECCS) sub-systems shall be operable with each subsystem comprised of, in part, one operable High Head Safety Injection (HHSI) pump, in Modes 1, 2 and 3.

L The footnote to T.S. 3.5.2 states, in part, that.the provisions of Specification 3.0.4 are not applicable for entry into Mode 3 for the Safety injection pumps declared inoperable pursuant to Specification 4.5.3.1.2 provided that the Safety Injection pumps are restored to operable status within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s-or prior to the temperature of one or more of the RCS cold

-legs exceeding 375 degrees F, whichever comes first.

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'he above, on September 12, 1990, STP Unit 1 entered Mode 3 L

with one E; sutsystem inoperable (as a result of the electrical breaker L

for the 1E t-igh Head Safety Injection pump being in the racked out position) and the subsystem was not restored to an operable status until the temperature of the RCS cold legs reached 385 degrees F.

This is a Severity Level IV. violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company (HL&P).is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTH: Document Control Desk,. Washington,

- D.C. 20555 with a copy to the Regional Administrator, Region IV, and if appli-cable, a copy to the NRC Resident lospector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should'te

' clearly marked as a " Reply to a Notice of Violation" and should include for each u

b violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation,-(2) the. corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an 9o1106o082 901101 ADOCK 0500 8

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Notice of' Violation >

order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be ta ken. Where good cause is shown. consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C.

2232, this response shall be submitted under oath or affirmation.

Dated at Arlington, Texas this 1st day of November 1990 1

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HL&P / NRC ENFORCEMENT CONFERENCE OCTOBER 5,1990 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

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AGENDA OCTOBER 5.1990 I

INTRODUCTION D. P. HALL l

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i EXCEEDED ALLOWABLE TEMPERATURE IN RCS WITH HHSI PUMP'1B INOPERABLE K. J. CHRISTIAN r

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l EVENTS WITH PERSONNEL ERROR AS A l

CONTRIBUTING CAUSE AND ACTIONS TO l

PREVENT RECURRENCE M. R. WISENBURG i

CONCLUDING REMARKS W. H. KINSEY l

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A1/011.N18 I

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i EXCFEnED AlI OWABLE TFMPERATURE IN RCS WITH HHSI PUMP 18 INOPtRABLE EVENT:

Technical Specifications require two High Head Safety injection (HHSI) pumps to be e

disabled in mode 4 operations for cold overpressure protection. However, Technical Specifications require all HHSI pumps to be operable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of entering Mode 3 or before exceeding 375'F during heatup.

On September 12,1990, Unit 1 was in the process of psikmising a plant heatup.

o At approximately 0714 hours0.00826 days <br />0.198 hours <br />0.00118 weeks <br />2.71677e-4 months <br />, Mode 3 was entered. At approximately 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br /> cold e

leg temperature exceeded 375 F. The plant heatup continued with the 1B HHSI pump out of service.

At 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, the condition was discovered. Plant heatup was secured at 389 F and e

the 1B HHSI pump was returned to service at 0807 hours0.00934 days <br />0.224 hours <br />0.00133 weeks <br />3.070635e-4 months <br />.

SAFETY SIGNIFICANCE:

HL&P reviewed STP analyses and determined that the plant remained within its design e

basis during the event, in this event, there were two operable HHSI trains capable of automatic actuation and e

the third capable of manual actuation. The plant was soberitical and all three trains of Low Head Safety injection were operable. Under the plant conditions at the time of the event (425. psi) there is sufficient cooling available in this configuration to provide time for operator action to manually initiate the third train of HHSI should it be necessary.

The safety significance of this event is minor as reflected by the Technical e

Specificatica action statement which allows the inoperability of one HMSI train for periods up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in Modes 1,2, & 3.

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EXCarnED A8 i OWABLE TEMPERATURE IN RCS WITH HHS1 PUMP 1B INOPERABLE' l

CAUSE:

Less than adequate supervisory overs;vi i and.commcgication.

e During the heatup, the Reactor Operator did not recall the specific temperature limit e

.(375*F) for operability of all three HHSI~ pumps nor did he track progress in implementing procedural steps during heatup.

CORRECTIVE ACTIONS:

I Appropriate action is being taken with respect to the Unit Supervisor. -

e The Reactor Operator was counseled in regard to his resporaibility to be alert to e

applicable procedural requirements.

Expsulations of management regarding adherence to pracedu.es and attention to e

detail will be reviewed with all Reactor Operators ant' Unit Supervisors.

i Other Reactor and Senior Reactor Operators will be retrained in the requirements for e

control of HHS1 pumps during heatup.

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EVENTS WITH PERSONNEL ERROR AS A CONTRIBUTING CAUSE t'

in challenging situations, our operations and maintenance personnel have performed e

well.

i Individually the events were not safety significant.

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Collectively, these events indicate a need to reinforce concepts of attention to detail, e

clear communications, procedural adherence and personal accountability.

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1 OPERATIONAL IMPROVEMENT Pl.AN e PLANT INCIDENTS

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- Valve lineups -

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- Procedures i

- Maintenance / operations i

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ELEMENTS OF PERFORMANCE IMPROVEMENT PROGRAM i

- Personal accountability

- Attention to detail; t

- Reduction of maintenance backlog

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- Establish training pipelines t

- Senior management observations t

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i SCJiEDULE FOR OPERATIONAL IMPROVEMENT PLAN OPERATIONAL IMPROVEMENT PLAN EVENTS e

- Meeting with Direct Reped and Dept Managers Sep 25,1990

- integrated action plan Oct 15,1990

- Near term actions Jan 01,1991 e

MILESTONES

- October 9,1990 NRC visit

- INPO Evaluation May 1991 l

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F Attendees, October 5,1990 Enfqrcement Conference in NRC Region _IV office, Arlins 'on, Texas Houston Lighting & Power Compar l D.P. Hall, Group Vice President, Nuclear W.H. Kinsey, Vice President, Nuclear Generation M.A. McBurnett, Nuclear Licensing Manager M.R. Wisenburg, Plant Manager, STPEGS G.H. Midkiff, Plant Operations Manager K.J. Christian, Operations Manager, STP Unit 1 City of Austin P.W. Golde, Joint Project lianager City of San Antonio M.T...Hardt, Director, Nuclear Division, City Public Service Central Power & Light Co.

Bryan McLauchlin, Supervisor, Site Monitoring NRC Region'IV-T.P. Gwynn, Acting Director, Division of Reactor Projects Johns P. Jaudon, Deputy Director, Division of Reactor Safety John L. Pellet, Chief, Operator Licensing Section, DRS L

Joseph I. Tapia, Senior Resident Inspector, STP Gary Sanborn, Enforcement Officer NRC Heaoquarters (by telephone)-

l James Linville, Office of Nuclear Reactor Regulation l

Renee Pedersen, Office of Enforcement 1

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