ML20059K937

Notice of Violation from Insp on 900730-0808.Violation Noted:On 900726,Steps 5.13.1 & 5.13.2 of Plant Procedure IPSP03-AF-0001,Rev 6, Auxiliary Feedwater Pump 11 Inservice Test, Performed Concurrently & Not Completely Independent

ML20059K937
Person / Time
Site:	South Texas
Issue date:	09/18/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059K934	List: ML20059K932 ML20059K937 ML20059K943
References
50-498-90-28, 50-499-90-28, NUDOCS 9009250265
Download: ML20059K937 (2)

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.^ l APPENDIX A  !

NOTICE OF VIOLATION

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i Houston Lighting & Power Company Dockets: 50-498  !

South Texas Project (STP), Units 1 and 2 50-499  ;

Operating Licenses:

NPF-76 NPF-80  :

During an NRC inspection conducted July 30 through August 8, 1990, two violations' of NRC requirements were identified. In accordance with the '

" General Statement of Policy and Procedure for NRC Enforcement Actions," '

10 CFR Part 2 Appendix C (1990) (Enforcement Policy), the violations are listed below:

A.- Failure to Follow Procedures for Independent Verification 10 CFR Part 50, Ap>endix B, Criterion V, requires, in part, that activities k affecting quality se accomplished in accordance with documented instructions. ,

Plant. Procedure IPSP03-AF-0001, Revision 6. " Auxiliary Feedwater Pump 11 i "CLOSE and LOCK Test Line Isolation .

.Valve Inservice Test,"

AF0040 andStep initial5.13.1, states (-2)," anTTtep 5.13.2, states "As a Data Sheet (sic) independent. verification have a second individual verify AF0040 is '

CLOSED a_nd LOCKED and initial Data Sheet (-2)."

Plant Procedure OPGP03-ZO-0004, Revision 11. " Plant Conduct of Operations " Step 4.4.11, requires that independent verifications shall be performed as prescribed by approved procedures or instructions in accordance with OPGP03-ZA-0010, " Plant Procedure Compliance, Implementation, and Review."

Plant Procedure OPGP03-ZA-0010, Revision 11. " Plant Procedure Compliance, Implementation, and Review " Step 3.3.2.1, states that the act of  ;

perfonning the independent verification must be completely separate and i independent of the initial alignment, installation, or verification.

Contrary to the above, on July 26, 1990, Steps 5.13.1 and 5.13.2 of Plant i Procedure 1 PSP 03-AF-0001, Revision 6. " Auxiliary Feedwater Pump 11 Inservice Test " were performed concurrently and were, therefore, not completely separate and independent. Th's resulted in a failure to detect that Test Line Isolation Valve AF00a0 was erroneously aligned in a locked >

open position. This error was diNovered following a reactor trip on ,

August 6,1990, when auxiliary fr.edwater from Auxiliary Feedwater Pump No.11 was circulated back to tLe auxiliary feedwater storage tank through the locked open valve instead of adding water to Steam Generator A as designed.

This is a Severity Level IV violation. (SupplementI)(498/9028-01)

Y $00$&pg PDC

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B. Failure to Provide Adequate Acceptance Criteria 10 CFR Part 50, Appendix B, Criterion V requires, in part, that procedures include appropriate acceptance criteria for detertnining that important activities have been satisfactorily accomplished.

South Texas Project Technical Specifications, paragraph 6.8.1.a. requires that procedures for activities identified in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented, and maintained. Paragraph 3 to Regulatory Guide 1.33 requires that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation be prepared for the chemical and volume control system (including letdown / purification system).

Contrary to the above, On August 6,1990, neither Operations Procedure 1 POP 02-CV-0004, " Chemical Volume and Control System Subsystem,"

Revision 8, or any administrative procedure contained adequate acceptance criteria for determining that the activities to place a mixed bed demineralizer in service had been satisfactorily accomplished.

This is a Severity Level IV violation. (Supplement 1)(498/9028-02)

Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violation if admitted,

2) the corrective steps which have been taken and the results achieved, 3)thecorrectivestepswhichwillbetakentoavoidfurtherviolations,and

4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas, this /fd day ofjp/aalil990

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