ML20092A770
| ML20092A770 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 12/31/1993 |
| From: | Cottle W HOUSTON LIGHTING & POWER CO. |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20092A377 | List:
|
| References | |
| FOIA-95-219 ST-HL-AE-100004, NUDOCS 9509110187 | |
| Download: ML20092A770 (5) | |
Text
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Y N ' N ' 5' W D W Houston Lighting & Power a
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I JAN - 6 December 31, 1993 j
ST-HL-AE-100004 File No.: G36
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,, y y 10CFR50
.z Mr. James M. Taylor Execiative Director for. Operations United States Nuclear Regulatory Commission 80 F Street, N.W.
Washington, D.C.
20001 South Texas Project Electric Generating Station Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 South Texas Proiect Operational Readiness Plan Clarification
Reference:
Correspondence from William T. Cottle (HL&P) to James M. Taylor (NRC), dated August 28, 1993 (ST-HL-AE-4556)
Dear Mr. Taylor:
On August 28, 1993 Houston Lighting & Power (HL&P) submitted the Operational Readiness Plan (ORP) for the South Texas Project.
Since then there has been significant progress on achieving the goals setforth in that plan.
Implementation of the ORP, as with most
- plans, has identified ref$nements and items requiring clarification.
These
- changes, summarized
- below, will be incorporated into Revision 1 of the Operational Readiness Plan.
This revision will be developed to support the return of Unit 2 to power operation.
In order to incorporate lessons learned from Unit 1, it will be submitted 45 days af ter Unit 1 attains the 100%
powar assessment plateau.
Technical Trainino Excerpt from Operational Readiness Plan, Revision 0, Page 24 e
Two additional personnel weaknesses identified during the evaluation of technical training were a less than adequate understanding of plant systems and an insufficient number of certified journeyman to accot.plish routine tasks.
To address both needs, an aggressive training schedule to be completed by the end of December 1993 has been implemented.
% - O.3 H :5 IR\\93 365.001 Project Manager on Behalf of the Participants in the South Texas Project 9509110187 950808-PDR FOIA COPELAN95-219 PDR
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Houston Lighting & Power Company South Texas Project Electric Generating Stati ST-HL-AE-100004 File No.: G36 Page 2 of 6 Clarification STP's 1993 goal associated with certification has been achieved.
This required 658 (173 electrical, 260 mechanical, 225 Instrumentation and Control) certifications to be achieved.
- Also, 81 incumbent journeyman needing system training have completed that instruction.
This ORP action is complete.
Supervisorv Traininc Excerpt from Operational Readiness Plan, Revision 0,
. age 24 To address weaknesses in performance of Maintenance Supervisors, a supervisor training program has been developed to ensure full compliance with ACAD 90-10,
" Guidelines for Maintenance Supervisor Selection and Development. "
Training using this program has been completed for Mechanical Supervisors and is scheduled to be complete for Electrical and I&C Supervisors by the end of 1993.
Clarification Training has been accomplished for those Mechanical, Electrical and Instrumentation and Control Supervisors (directly supervising craft activities),
incumbent to their positions prior to the reorganization of the maintenance department to support unitization.
Training of new supervisors is scheduled for completion during 1994.
Only supervisors that directly supervise craft activities are included in this training.
Performance Measures Used to Monitor Maintenance Effectiveness e
Excerpt from Operational Readiness Plan, Revision 0, Page 25 Indicators to be used to monitor station material condition are (only two of seven listed):
- Main Control Board deficiencies.
(Goal:
less than 10)
PM deferral rate.
(Goal: less than 20)
- R\\93-365.001
- Houston Lighting & Power Company
-1 South Texas Project Electric Generating Station ST-HL-AE-100004 File No.: G36 Page 3 of 6 e
Clarification
- Main Control Board Deficiencies The goal set for this category is currently less than 10 prior to power operation.
However, it should be recognized that some MCB deficiencies will-be " work complete" but not in-service because post-maintenance / operability tests require at power conditions.
Also, because of the length of time the unit has been shutdown with instruments out of service, it is anticipated that as mode changes occur the number of deficiencies will temporarily rise above 10.
Therefore, the goal is being restated as follows:
No outstanding deficiencies that adversely effect Operations i
ability to effectively monitor plant conditions at each mode; with a goal of < 10 at the 100% power assessment plateau.
Preventive Maintenance Deferral Rate Although the goal of less chan 20 PM deferrals has been
- achieved, further evaluation has indicated that a fixed number is not an effective nor practical indicator for long term success.
The new goal, consistent with the STP Business Plan, is to achieve and maintain a PM Deferral Rate of < 5%.
Eauinment Labelino e
Excerpt from Operational Readiness Plan, Revision 0, Page 35 1
A comprehensive relabeling program incorporating the guidelines of INPO Good Practice OP-28, " System and Component Labeling" and EPRI NP-6209, " Effective Plant Labeling and Coding" is being implemented.
Program requirements will be in-place and a pilot program involving the Standby Diesel Generators will be completed by the end of 1993.
e ClarificatiQD The pilot program involving the Standby Diesel Generator is limited to mechanical components and instrumentation for the engine. The electrical portion of the Standby Diesel Generator relabeling effort will be in conjunction with the plant electrical distribution systems.
Support systems, such as the air start system, also are not included in the initial program.
7 IR\\t3 365.001
e a
8 Houston Lighting & Power Company South Texas Project Eicctric Generating Station ST-HL-AE-100004 File No.: G36 Page 4 of 6 Preventive Maintenance Procram Excerpt from Operational Readiness Plan, Revision 0, Page 35 o
A Business Plan strategy has been developed to address plant reliability improvements. The strategy will assess the existing Preventive Maintenance and Reliability Centere'd Maintenance (RCM) programs to foster the development of.a comprehensive reliability-based, predictive / preventive maintenance program with a documented basis. The strategy will also provide for the review of all existing PMs to ensure they are applicable and effective, and an evaluation of the PM program process, including
- software, to identify elements that require enhancement.
This effort will be accomplished through an integrated approach composed of the performance of detailed EPRI style RCM on approximately 10 systems,- streamlined RCM on approximately 40 systems, and a comprehensive review of PM tasks to develop a complete PM basis, o
Clarification The description of the Reliability Centered Maintenance (RCM) program provided in the ORP was based upon the draft plan submitted for the STP Business Plan.
At the time the ORP was submitted, the business planning process was ongoing.
As a result of discussions during this process and input from other utilities that utili' zed the in-depth RCM process, it was determined that more benefit would be gained by STP by changing the performance of detailed the original proposal from:
EPRI style RCM on approximately 10 systems, streamlined RCM on approximately 40 systems, and a comprehensive review of PM tasks to develop a complete PM basis. " to the perforuance of detailed EPRI style RCM on three systems, streamlined RCM on the 47 remaining systems, and a comprehensive review of PM tasks to 1
develop a complete PM basis."
i Assessment Proces_q The assessment schedule, as described on page 14 of the ORP, calls for an assessment milestone af ter one week of full power operation.
3 After further consideration, it was decided that an assessment i
af ter 10 days of full power operation would provide more meaningful information.
Therefore, as a minimum, formal assessments will be conducted prior to Mode 4, prior to criticality, prior to power j
j ascension above 50% power, and after 10 days of full power i
operation.
IR\\93 365.001 t
e 4
Houston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-100004 File No.. G36 Page 5 of 6 As STP nears resumption of power operation, it may become necessary to refine other goals presented in the Operational Readiness Plan.
If this is necessary, the NRC will be promptly notified.
If you have any questions or comments, please contact Mr.
J.
J.
Sheppard at (512) 972-8757 w rc.ke.u W.
T.
Cottle Group Vice President Nuclear IR\\93 365.001
p mC820 UNITED STATES J,1 NUCLEAR REGULATORY COMMISSION
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REGION IV g
I 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 760114064 JAN I 21994 MEMORANDUM FOR:
James M. Taylor, Executive Director for Operations FROM:
James L. Milhoan, Regional Administrator, Region IV
SUBJECT:
STATUS
SUMMARY
OF REGION IV STAFF ACTIONS RESULTING FROM THE DIAGNOSTIC EVALUATION AT THE SOUTH TEXAS PROJECT In response to your memorandum of August 3, 1993, I am providing the attached status sumary of Region IV staff actions resulting from the Diagnostic Evaluation at the South Texas Project. This summary updates my memorandum of November 2, 1993, and reports completion of the ste.ff actions assigned to Region IV.
To coordinate the NRC activities prior to authorization of unit restart, the South Texas Proje-t Restart Panel is continuing to work under the guidance of Manual Chapter 0350 using a plant-specific Restart Action Plan.
If there are any questions regarding the Restart Action Plan or the staff action items, please contact me or have your staff contact Bill Johnson (817)860-8148.
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N b. Milhoan Regional Administrator
Attachment:
Status Summary of Regional Staff Actions
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Memorandum for James M. Taylor 2
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Attachment:
E. Jordan AEOD (MS 3701)
S. Rubin, AE0D (MS 5219)
T. Murley, NRR (MS 12G18)
J. Callan, NRR (MS 12Gl9)
S. Collins, RIV A. B. Beach, RIV J. Roe, NRR (MS 13E4)
E. Adensam, i;RR (MS 4E4)
W. Russell, NRR (MS 12G18)
W. Johnson, RIV i
S. Black, NRR (MS 13H15)
L. Kokajko, NRR (MS 13E16)
E. Imbro, NRR (MS 9A1)
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ATTACHMENT 1 Status Summary of Regional Staff Actions Staff Action 1.(a):
Assess operating staff workload issues at STP and the management actions to resolve them.
Status:
This restart issue has been resolved.
The licensee's Operational Readiness Plan addressed several initiatives to increase staffing and to reduce the administrative workload of the operators. The Region IV inspection in this area was performed in two segments. The first segment was conducted the week of November 1, 1993, and the second segment was conducted the week of November 29, 1993. NRC Inspection Reports 50-498/93-40; 50-499/93-40 and 50-498/93-41; 50-499/93-41 were issued on December 1 and December 16, 1993, respectively. The first inspection found that the licensee had made substantial progress toward resolving the restart issue.
The second inspection focused on implementation effectiveness.
This inspection found that the licensee's corrective actions have been effective in correcting the problems of marginal operator staffing. These actions included relieving the operating crew of administrative burdens by transferring duties to the newly formed operations work control group; adding a sixth crew of operators which will begin watch rotation in January 1994; training 20 additional non-licensed operators and placing additional non-licensed operators on each crew; transferring certain duties from the operations department to the technical services department, and providing engineering support to operations and maintenance around the clock. Open followup items involve NRC evaluation of the implementation of the 6-shift watch rotation in January 1994.
Staff Action 3:
Conduct a followup inspection of the fire protection deficiencies at STP.
Status:
The following two restart issues have been resolved:
1)
Adequacy of fire brigade leader training and qualifications, and 2) Adequacy of the fire protection computers and software, the licensee's success in reducing the number of spurious fire protection system alarms, and other fire protection hardware problems.
The first segment of the Region IV inspection of these issues was conducted during the week of October 18, 1993.
Results of this inspection (Inspection Report 50-498/93-37; 50-499/93-37 issued on November 23,1993) were favorable, indicating considerable progress. A followup inspection was
' conducted the week of December 13, 1993. Results of the inspections are summarized below.
i 1.
Fire Brigade Team Leader Training The concerns of the fire brigade leaders' knowledge of facility safe shutdown systems, and the impact on the operations staff has been reviewed by Region IV staff.
The region concluded that the current fire brigade leader training program meets the regulatory requirements of Appendix R to 10 CFR 50 regarding the STP fire brigade leaders' knowledge of safe shutdown 4
systems. The licensee's effort to validate the current program learning objectives by a comparison review against the licensed operator training program was effective. Upon completion of the design and implementation of a new training program that is being developed, the licensee's training program will far exceed industry standards. The licensee's current effort to provide extra personnel, by training six i
additional personnel qualified to perform as fire brigade leader, will remove all burden from plant operations personnel, to staff the position of fire brigade leader.
2.
Fire Protection Computer Alarm System Regional personnel determined that the licensee's efforts to significantly reduce the distraction of control room operators by the fire protection computer alarm system had been successful. The number of spurious alarms noted during the DET was characterized as 20-30 per day. During the followup inspection, inspectors observed 4-5 alarms per day. All alarms were being trended to identify additional problems i
with additional computer alarm points. There was indication that information retrieval had been improved due to the improved computer alarm descriptions.
There was an apparent increase in operator sensitivity to the information provided by the fire detection system and control room operators appeared to De less distracted. The conclusion was reached that the performance of the fire detection and computer system had been significantly enhanced by the numerous hardware and software changes. Startup of i
Unit I should not be delayed because of this issue.
The licensee will need to address the Unit 2 fire protection computer alarm system separately.
)
c.
3.
Fire Protection Systems Service Request Backlog 1
Region IV inspectors concluded that the licensee had identified all the work necessary tc address the material condition of the fire detection and suppression systems. A determination of work progress and quality was made during the followup inspection to assess the improved condition of the fire protection systems. This inspectior, found that STP management had performeo effectively in addressing the degraded material condition of the Unit I and common fire protection systems.
The licensee's process had identified a significant number of new hardware 4
deficiencies, which were being worked to completion.
A significant portion of the work (80-85 percent) had been completed and the remaining items were being completed at a higher rate than originally expected.
The region concluded that the status of the Unit <1 and s
common fire protection systems maintenance and repair backlog should not be an issue affecting the scheduled d
startup of Unit 1.
t 4.
Control of Transient Combustibles The inspection results showed that the licensee had I
increased empnasis on control cf transient combustible i
material. This effort in conjunction with the licensee's existing administrative procedures was providing a more effective program.
During plant tours, the inspectors found that the plant was generally clean and that outage work areas were well policed. The transient combustibles observed were within the combustible loading for the areas.
Continued effectiveness of the transient combustible i
control program will require close control and involvement by licensee management with specific j
emphasis on generating a sense of individual responsibility by all employees.
The control of transient comoustibles should not impact the scheduled startup of either unit.
5.
Degraded Fire Barrier Penetration Seals The inspection results indicated that the licensee had taken appropriate and timely corrective action for the i
shrinking and cracking of the hydrosil fire barrier penetration seals.
The bulk of this action involved creating, testing, and implementing a valid repair process. Since the per.etration seal desiccation process was time dependent, the failures extended over
, a long period and show a rapid decrease in failure l
rate, from 27 percent in 1990 to 6.1 percent in 1991 and 3.9 percent in 1993. Regional inspectors agree with the licensee's opinion that the most significant seal degradation has already taken place.
Further degradation should be very limited, and will be repaired on a case by case basis, when identified within the normal surveillance program. There was no evidence that the evaluation, investigation, and repair processes were unduly delayed.
It appears that management was well aware of the problem and supported the recovery efforts.
Staff Action 8:
Review and evaluate the licensee's response to the j
diagnostic evaluation report for completeness.
Prepare an appropriate reply for ED0 signature.
i Status:
This item was completed with the issuance of the EDO letter to the licensee on November 18, 1993.
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REGION IV 8
611 RY AN PLAZA DRIVE, SUITE 400 8
AR LINGTON, T E XAS 76011 8064 v
L. J. Callan Regional Administrator FROM:
Samuel J. Collins South Texas Project Restart Panel
SUBJECT:
COMPLETION OF SOUTH TEXAS PROJECT UNIT 1 CONFIRMATORY ACTION LETTER ITEMS AND RESTART ACTION PLAN STATUS The purpose of this memorandum is to document the discussions and presentation to you on February 15, 1994, which informed you of the status of Houston Lighting & Power Company's (HL&P) actions to implement the South Texas Project (STP) Confirmatory Action Letter (CAL 4-93-048) dated October 15, 1993, and the status of tasks associated with the STP Restart Action Plan for Unit 1.
Confirmatory Action Letter On February 3,1993, following a reactor trip, the Unit 2 turbine-driven auxiliary feedwater pump started and immediately tripped on overspeed. On February 4,1993, Unit I was required to shut down as a result of repeated i
failures of the turbine-driven auxiliary feedwater pump to start on demand and operate without tripping on overspeed. As a result of these problems, NRC issued a Confirmatory Action Letter (CAL) to HL&P on February 5, 1993, and dispatched an augmented inspection team (AIT). The CAL required resolution of the overspeed trip condition affecting the turbine-driven auxiliary feedwater pumps and a briefing of NRC staff prior to restart of the unit.
In addition to the AIT activities, several special inspections were conducted at STP, including a diagnostic evaluation by the NRC office of Analysis and Evaluation of Operational Data conducted during the period of March 29 to April 30, 1993. The findings of these reviews resulted in supplements to the CAL issued on May 7, 1993 (CAL 4-93-04), and October 15, 1993 (CAL 4-93-04B).
These supplements included issues that NRC considered of sufficient scope and safety significance to require resolution prior to either unit being restarted (Enclosures 1, 2, and 3).
Licensee Actions In addition to the hardware related issues at STP, the NRC required HL&P to address programmatic problems, including work backlogs, postmaintenance testing shortcomings, outstanding modifications, operations staffing adequacy, fire protection equipment and training, management effectiveness in identifying, pursuing, and correcting plant problems, and the results of internal restart readiness reviews.
In response, the licensee developed the J
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L. J. Callan 1 Based on the~ independent inspections and reviews conducted by the NRC staff and described in Enclosure 4 (STP Restart Action Plan), the licensee has satisfactorily completed the items specified in the CAL.
Restart Panel Meeting The STP Restart Panel met on February 15, 1994, in accordance with NRC Manual Chapter 0350, " Staff Guidelines For Restart Approval," to review outstanding issues requiring resolution prior to restart of Unit 1.
Based on the independent inspection and reviews conducted at STP and described in, the satisfactory resolution of those items addressed in the February 14, 1994, public meeting, and confirmation of the completion of remaining issues on February 15, 1994, the Panel recommended approving the resumption of operation of STP, Unit 1, in accordance with the facility Technical Specifications.
In accordance with the February 3, 1994, memorandum from Director, DRP to the STP Restart Panel augmented inspection team coverage of the unit restart will commence about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to entry into Mode 2 operations and will continue until Unit I has demonstrated successful operation.
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Enclosures:
1.
CAL, February 5, 1993 2.
CAL, May 7, 1993 3.
CAL, October 15, 1993 4.
STP Restart Unit 1 Action Plan, Revision 4 l
cc w/ enclosures:
Houston Lighting & Power Company ATTN: William T. Cottle, Group Vice President, Nuclear P.O. Box 289 Wadsworth, Texas 77483 Houston Lighting & Power Company ATTN: James J. Sheppard, General Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483
g@ NG UNITED STATES
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REGION IV
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611 RYAN PLAZA DRIVE. SUITE 400 y,s f*
A RLINGTON, T E XAS 76011 8064 MAR - 3199 MEMORANDUM FOR:
L. J. Callan Regional Administrator FROM:
Samuel J. Collins South Texas Project Restart Panel r
SUBJECT:
COMPLETION OF SOUTH TEXAS PROJECT UNIT 1 CONFIRMATORY ACTION LETTER ITEMS AND RESTART ACTION PLAN STATUS The purpose of this memorandum is to document the discussions and presentation to you on February 15, 1994, which informed you of the status of Houston Lighting & Power Company's (HL&P) actions to implement the South Texas Project (STP) Confirmatory Action Letter (CAL 4-93-048) dated October 15, 1993, and the status of tasks associated with the STP Restart Action Plan for Unit 1.
Confirmator_y Action Letter On February 3,1993, following a reactor trip, the Unit 2 turbine-driven auxiliary feedwater pump started and immediately tripped on overspeed. On February 4, 1993, Unit I was required to shut down as a result of repeated failures of the turbine-driven auxiliary feedwater pump to start on demand and operate without tripping on overspeed. As a result of these problems, NRC issued a Confirmatory Action Letter (CAL) to HL&P on February 5, 1993, and i
dispatched an augmented inspection team (AIT). The CAL required resolution of the overspeed trip condition affecting the turbine-driven auxiliary feedwater pumps and a briefing of NRC staff prior to restart of the unit.
In addition to the AIT activities, several special inspections were conducted at STP, including a diagnostic evaluation by the NRC office of Analysis and Evaluation of Operational Data conducted during the period of March 29 to April 30, 1993. The findings of these reviews resulted in supplements to the CAL issued on May 7, 1993 (CAL 4-93-04), and October 15, 1993 (CAL 4-93-04B).
These supplements included issues that NRC considered of sufficient scope and safety significance to require resolution prior to either unit being restarted (Enclosures 1, 2, and 3).
Licensee Actions In addition to the hardware related issues at STP, the NRC required HL&P to address programmatic problems, including work backlogs, postmaintenance testing shortcomings, outstanding modifications, operations staffing adequacy, fire protection equipment and training, management effectiveness in identifying, pursuing, and correcting plant problems, and the results of internal restart readiness reviews.
In response, the licensee developed ther J
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uperational Readiness Plan submitted to the NRC in August 1993, which described specific actions to be taken prior to the resumption of power operation. Additionally, longer-term actions were described in the Business i
Plan submitted to NRC -in October 1993. HL&P has initiated changes in the STP i
management from the Group Vice President, Nuclear to the Plant Managers, including a reorganization of the Nuclear Generation department.
a On January 29, 1994, HL&P requested a meeting to brief the NRC on the status j
of the issues described in the February 5, 1993, CAL and its supplements.
In the licensee's written submittal they described the actions taken in response to NRC concerns and included a summary of actions remaining prior to j
l resumption of power operation. A public meeting was conducted at the site on February 14, 1994, and a briefing of the STP Restart Panel was conducted by teleconference on February 15, 1994, during which the licensee confirmed actions taken in preparation for the resumption of power operation of STP, Unit 1.
4 l
NRC Actions l
The NRC Region.IV Regional Administrator chartered the STP Review Panel on March 11, 1993.
The STP Review Panel is composed of regional and program office managers and is to:
(1) assure that a consistent approach to issues is i
being identified at STP and attempt to reach an agency consensus and united j
approach to addressing the problems at STP; (2) assure that the followup on safety significant issues is being properly coordinated and scheduled; 4
(3) schedule significant meetings and inspections; (4) assure that the views and concerns of different NRC offices are properly addressed; and (5) assure proper coordination for the followup of issues that are identified by the Diagnostic Evaluation Team (DET) inspection.
On April 12, 1993, it was determined that NRC Inspection Manual Chapter 0350,
" Staff Guidelines for Restart Approval," was applicable for STP because of its extended shutdown and previous indications of serious deficiencies in licensee management effectiveness. The STP Review Panel assumed the role and responsibilities of the STP Restart Panel and issued the STP Restart Action Plan (Enclosure 4) which includes expected NRC actions required to be taken before restart of the STP Units.
In addition to the focused inspections conducted at STP since the shutdown of Units 1 and 2, an independent Operational Readiness Assessment Team (ORAT) inspection, led by the Special Inspection Branch of the Office of Nuclear Reactor Regulation, was conducted from December 6-10, 1993, and January 12-21, 1994. At the exit meeting conducted on January 21, 1994, the licensee committed to the resolution of issues regarding:
(1) configuration management; (2) motor-operated valve opening under system pressure; and (3) surveillance weaknesses. The ORAT concluded that, pending the results of licensee actions concerning the above three items, the ORAT team would be generally supportive of a' restart of Unit 1.
l l
L. J. Callan.
i Based on the independent inspections and reviews conducted by the NRC staff and described in Enclosure 4 (STP Restart Action Plan), the licensee has satisfactorily completed the items specified in the CAL.
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Restart Panel Meetina The STP Restart Panel met on February 15, 1994, in accordance with NRC Manual 4
Chapter 0350, " Staff Guidelines For Restart Approval," to review outstanding
. issues requiring resolution prior to restart of Unit 1.
Based on the independent inspection and reviews conducted at STP and described in j, the satisfactory resolution of those items addressed in the February 14, 1994, public meeting, and confirmation of the completion of -
remaining issues on February 15, 1994, the Panel recommended approving the resumption of operation of STP, Unit 1, in accordance with the facility Technical Specifications.
In accordance with the February 3, 1994, memorandum from Director, DRP to the STP Restart Panel augmented inspection team coverage of the unit restart will commence about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to. entry into Mode 2 operations and will continue until Unit I has demonstrated successful operation.
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- STP Restart Panel
Enclosures:
l.
CAL, February 5, 1993 2.
CAL, May 7, 1993 3.
CAL, October 15, 1993 4.
STP Restart Unit 1 Action Plan, Revision 4 cc w/ enclosures:
Houston Lighting & Power Company ATTN: William T. Cottle, Group Vice President, Nuclear 4
P.O. Box 289 Wadsworth, Texas 77483 Houston Lighting & Power Company ATTN: James J. Shcppard, General Manager Nuclear Licensing P.O. Box 289 l
Wadsworth, Texas 77483 4
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Q L. J. Callan City of Austin Electric Utility Department ATTN:
J. C. Lanier/M. B. Lee 721 Barton Springs Road Austin, Texas 78704 City Public Service Board ATTN:
K. J. Fiedler/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 Central Power and Light Company ATTN:
G. E. Vaughn/T. M. Puckett P.O. Box 2121 Corpus Christi, Texas 78403 INP0 Records Center 700 Galleria Parkway Atlanta, Georgia _ 30339-5957 Mr. Joseph M. Hendrie 50 Bellport Lane Bellport, New York 11713 Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, Texas 78756 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
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L. J. Callan,
Houston Lighting & Power Company ATTN:
Rufus S. Scott, Associate General Counsel P.O. Box 61867 i
Houston, Texas 77208 i
Shaw, Pittman, Potts & Trowbridge ATIN. Joseph R. Egan, Esq.
2300 N Street, N.W.
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Washington, D.C.
20037 I
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L. J. Callan MAR - 31994 E-Mail report to D. Sullivan (DJS) bec to DMB (IE01) bec distrib. by RIV:
L. J. Callan Resident Inspector Branch Chief (DRP/A)
Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPB RIV File Project Engineer (DRP/A)
R. Bachmann, OGC, MS: 15-B-18 Branch Chief (DRP/TSS)
A. Thadani, NRR M/S 8E2 W. Russell, NRR M/S 12G18 J. Roe, NRR M/S 13E4 E. Adensam, NRR M/S 13E4 RIV OEDO Coordinator, M/S 17G21 STP Restart Panel Members C. Sudman, DRP ni RIV:RPC*
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ENCLOSURE 1 U^'ITED STATES pa rtig<>?,
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REoloN IV
,8, 611 RYAN PLAZA oRtVE. SUITE 400 o,
ARuNGToN, TEXAS 760118064 j
FEB - 5199G Docket 50-498 50-499 License NPF-76 NPF-30 CAL 4-93-04 Houston Lignting & Power Company ATTN:
Donald P. Hall, Group Vice President, Nuclear P.O. Box 1700 Houston. Texas 77251 4
SUBJECT:
CCNFIRMATORY ACTION LETTER Pursuant to our telephone conversation on February 4. 10'1, it is our understancing that South Texas Project. 'Jnits 1 and 2, 11 not be taken critical until you have briefed the NRC staff of the results of your efforts to correct the overspeed trip condition that is affecting the turbine-driven auxiliary feedwater pumps.
Pursuant to Section 182 of the Atomic Energy Act. 42 U.S.C. 2232 and 10 CFR 2.201 you are requireo to rc:
- . me immeoiately if your understanding differs frem that set forth aoove.
Issuance of :his Confirmatory Act1:n.n er does not preclude issuance of an order forma".1 zing the above commitment: ar reouiring other actions on the part of the licensee.
Nor does it preciuce the NRC from taking enforcement action for violat*:ns of NRC reoutrements.na: may have prompted the issuance of this letter.
- n addition failure to taxe
.e acticns addressed in this Confirmatory Action Letter may resuit 9 enforcement action.
The responses directed by :hls lettsr ice not suoject to the clearance procedures :f the Office of Manageren: ino Budget as required by the Paperwork a tion of 1980. Dub. L. No. H-511.
Reduction c
CERTIFIED MAIL - RETURN RECEIPT RECUES ED
. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.
Sincerely,
/1 s
/amesL.Milhoan egional Administrator 1
CC:
4 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 Austin, Texas 78767 City Public Service Board ATTN:
R. J. Costello/M. T. Hardt P.O. Box 1771 San Antonio. Texas 78296 Newman i Holtzinger. P. C.
ATTN: Jack R. Newman, Esq.
1615 L Street. NW Washington. D.C.
20036 Central Power and Light Company ATTN:
D. E. Ward /T. M. Puckett P.O. Box 2121 Corpus Christi. Texas 78403 INP0 Records Center 1100 Circle 75 Parkway Atlanta. Georgia 30339-3064 Mr. Joseph M. Henorie 50 Bellport Lane Bellport. New York 11713
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Bureau of Radiation Control j'
State of Texas-1101 West 49th Street Austin, Texas 78756 a
Judge, Matagorda County Matagoroa County Courthouse 1700 Seventh Street i
Bay City, Texas. 77414 Licensing Representative Houston Lighting & Power Company Suite 610 Three Metro Center e
Bethesda, Maryland 20814 i
Houston Lighting & Power Company ATTN: Rufus S. Scott, Associate General Counsel l
P.O. Box 61867 Houston. Texas 77208 NRC Public Document Room Texas Raoiation Control Program Dirsc:or a
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en UNITED STATES ENCLOSURE 2 g A cs;9'e,\\
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NUCLEAR REGULATORY COMMISSION
- [
Pf R EGION IV r
s11 RY AN PLAZA oAIVE.SulTE 400
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AR LlNGToN. TEXAS 760114084 o....
14AY - 7 19E Dockets:
50 498 50 499 Licenses: '4PF-76
'iPF-80 CAL 4-93-04 Houston Lignting & Power Company ATTN:
William T. Cottle. Group Vice President. Nuclear P.O. Box UC0 Houston. Texas 77251
SUBJECT:
CC.'lFIRMATORY ACTION LETTEP. IUPDLEMENT This supplements my Confirmatory Act::n.etter :f Feoruary 5. 1993. wnich noted Houst:n Lighting i Power Company':.anacement agreement that South Texas Project. Units 1 ano 2. will not be ta<en critical unti'l the NRC Staff has been briefeo on the results of your ef#:rts to :orrect the overspeen trip conoition wnich affected the turoine-cc cen auxiliary feedwater pumps.
Because of *.re numoer of issues that ave reen 'dentified both by your staff ano the NRC. jou agreeo, in cur telect:-e :anversation of May 7.1993. to include the #3ilowing additiona; too'::
four riefing of the NRC staff which will :e scheouleo later.
he 5:ation Prooie,.eocr : : cess. nci;oing process e
morovements, thresnoic. 1 : ne esuits of your review of existing reports #:r iss.ss 1-fect: g soulement operao11ity and safe oiant operat::n:
e
~he Service Reaues: cacKi:;.
nciuc ng -eouction accomolisned
- uring :he current :utagas in jour -eview of outstanoing service
- eouests for issues affe::- : ecu:: ent :ceraoility, safe olant
- ceration. and coerator c --counes:
e
'he postmaintenance tes: : ::-im.
ticcing corrective ac:: ens in esponse to recent.iolat : s ino ::ner rocess improvements and
- ne basis for your :onf :se:s :nat ecuioment removed from service
- ar maintenance s :rocer estore :: an operable status:
he outstancing cesign eac '*:stions. temocrary modifications, and e
- ther engineering racKic;
.5 s.
- !ualng your review of these
- cr issues affecting eaul: en: aceracliity, safe -lant coeration.
ino operator wors-arounes:
g
Houston Lignting i Power Company.
Staffing in the operations department. "ncluding adequacy of e
current staffing levels. plans for eoiacing planned ana anexpected losses to succort safe :iant :tartup and operation. and
- ne aoecuacy of s:affing uncer emercency conditions:
~he status of fire origaoe leaaer raining, including verification o
. hat tnis training meets regulatory reautrements:
~he status of the fire protection ::mouters. including reliability e
3 and functionality of operator inter ace:
Management effectiveness in icent1 ying. pursuing, and correcting 3
e
- iant :roblems. :ncluding any plans #ar naecendent reviews: and
~he results of your internai restar remainess reviews.
e It is important that a thorougn review of the :scKiogs in the areas of Service Reauests, engineering items. ana Stat:cn Probism Recorts be conducted to assure that anKnown eouipment operacliity prooiems are identifiea ano correctea.
2.n example of a recent :rcolem affe:::ng safety-relatea equipment i
operability anich.ad oreviously been centifisc in a Service Reouest was the missing screws in the Qualifiea Disciay Processing 5/ stem.
Weaknesses in the postmaintenance testing program have resuitea
- nocerable equipment being returned t: service.
The many outs analng des ;n coifications should be carefully :r orit :sa to ensure tha:
. se wi--
oortance to safety of operations are impiementea :r. i tire:.
anner 1.a. rat no potential operaoili:.
ssues exist.
n '.iew of e mare:nai staf #
g ;e.e
..ne :: era;;:ns department. it is
- moortant
.a; unnecessary :ur: ens ino ::strac: :ns :e removea ana inat you nave a piar. n ciate to prov,:e for ::ntingent is 1.o losses.
Adeauacy of the initial tra:.1no 3:r fire cr*: ace lei:er: :s 1- ::en issue and their overdue reaualift:1:::n'Irl:ning has issulte: n in er.1 :groen being placea on noniicensec :cerat:rs.
Rei4a:11ity :" ano coset:cr nterf ace difficulties with the #
e orotect:cn comcuters 11 : acea 1 ex:ra buraen on operators ano could dela esconse to a f' e :n tre :iant.
e :ats:anding temocrary moaificat :-s.vnien recuire 1::1tiona : erat: 1:: ans. sucn as manuai coeration :" automatic contr: ' syste s. :.noui: :e estorea to minimize their impact on e eff ::ency of ::erator!.
Weaxnesses n orooiem ident:# cation. :rcolem trarting, safety imoact evaluation.
cot cause analys s anc ::rrecti.e ic ::n orocesses have oeen ooservea - :oth.ne station :-cois-' ;e0Cr :r :ss! 100 in the Service Request process.
no1 cat 1rg ineffect:.e manage ert of - ese areas.
This list:r.o of t:cics for ::stussten e
nter:sc :: focus the briefino on staff concerns involving potential tifet. :ss es.
- other such topics are
'identifiec :rior :: the brief ng. you.viil De 1:vissa by letter or telephone.
Please infor1 me wnen your staff has ace s$gr. " cant progress in aadressing
'24.+.+
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mp,,.
Houston ugnting & Power-Company f these issues so I can scheduis a special inspection prior to the briefing.
All provisions of the February 5.1993. letter remain in effect.
If you have any quest 1ons.. please feel free to c:ntact me or Bill Beach of my staff.
Sincerely.
L.
i lhoan Jegional administrator cc:
Houston Li:nting & Power Company ATTil:
Wiiiiam J. Jumo. Manager Nuclear Licensing P.O. Box 2*9 Waoswortn. ~exas 77A83 City of Aust*n Electric St11ity Department ATTil:
J.
. Lanier M. B. Lee P.O. Box '088 Austin Texas 78767 City Pubit: fervice Board ATTil:
R. 2. :osteiio,M. T. -ar:t D. 0. Box ;"'.
San Anton :. 'exas 3296
'lewman :. -.t:1nger. 3 C.
ATTN:
. acs :.. tiewman. Eso.
1615 L Street. NW
'iasningt:n. :.C.
20036 Central ::wer ano L:gnt Compar.-
AT *il:
D. E. Aaro. T 'i. PucKe".
P.J. Box l'::
Carous Chr sti. Texas 78403 I!1P0 Records lister 1:00 Circle ~5 Parxway Atlanta. leorgia 33339-3064 Mr. Joseen ". Henor e 50 Belloort :.ane Seilport. ';ew (ork *1713
Houston Lignting &. Power Company !
Bureau of Radiation Control State of Texas
~
1101 West 19th Street Austin, Texas 78756 Judge,'Matagorda County Matagorda County Courthouse 1700 Seventn Street Bay City, Texas 77414 Licensing Reoresentative Houston Lignting & Power Company Suite 610 Three Metro Center Cethesda. Maryland 10814 Houston Lignting & Power Company ATTN:
Rufus S. Scott. Associate 4
General Counsel P.O. Box 51267 i
Houston. Texas 77208 i
4
pm #84 UNITED STATES 9
ENCLOSURE 3 d
- g NUCLEAR REGULATORY COMMISSION y
g j
RecloN iv 8
611 RYAN PLAZA DRIVE. SUITE 400 o,
v ARLINGTON TEXAS 760114064 f
OCT I 5 IE Dockets: 50-498 50-499 Licenses: NPF-76 NPF-80 CAL 4-93-04B Houston Lighting & Power Company ATTN: William T. Cottle, Group Vice President, Nuclear P.O. Box 1700 Houston, Texas 77251
SUBJECT:
CONFIRMATORY ACTION LETTER SUPPLEMENT 2 This is the second supplement to my Confirmatory Action Letter of February 5, 1993, which noted Houston Lighting & Power Company's management agreement that South Texas Project, Units 1 and 2, will not be taken critical until the NRC staff has been briefed on the results of your efforts to correct the overspeed trip condition which affected the turbine-driven auxiliary feedwater pumps.
As discussed with Mr. John Groth in a public meeting in Arlington, Texas, on October 5, 1993, the following topics have been identified as additions to the issues which must be resolved prior to startuo of either South Texas Project unit.
In a telephone conversation on October 15, 1993, you acknowledged these issues and agreed that these topics would be addressed in your briefing of the NRC staff in a meeting to be scneduled prior to unit startup.
The additional topics are:
Effectiveness of the SPEAXOUT program; Standby diesel generator reliability; Essential chiller reliability; The system certification program; Reliability and operability of the feedwater isolation bypass valves; Adequacy of tornado dar.ioer testing; and Acceptability of the emergency prepareoness accountability drill results.
These are not new issues, but they were considered to be significent following reviews of the Diagnostic Evaluation Report, your Operational Readiness Program, the allegation process, and recent NRC inspection findings. The complete results of these reviews are documented in NRC Inspection Report 50-498/93-31; 50-499/93-31.
This listing of topics for discussion is CERTIFIED MAIL - RETURN RECEIPT RE0 VESTED Q\\ OCD G
Houston Lighting & Power Co. intended to focus the briefing on staff concerns involving potential safety issues.
If other such topics are identified prior to the briefing, you will be advised by letter or telephone.
Please inform me when your staff has made significant progress in addressing these issues so I can schedule special inspections prior to the briefing.
All provisions of the February 5, 1993, letter and its supplement of May 7,1993, remain in effect.
If you have any questions, please feel free to contact me or Mr. Art Howell of my staff.
Sincerely, es
. Mi
/ Regional A r
CC:
Clouston Lighting & Power Company ATTN: James J. Sheppard, General Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483 City of Austin Electric Utility Department ATTN:
J. C. Lanier/M. B. Lee 721 Barton Springs Road Austin, Texas 78704 City Public Service Board ATTN:
K. J. Fiedler/M. T. Hardt i
P.O. Box 1771 l
San Antonio, Texas 78296 Newman & Holtzinger, P. C.
ATTh: Jack R. Newman, Esq.
1615 L Street, NW Washington, D.C.
20036 Central Power and Light Company i
ATTN:
D. E. Ward /T. M. Puckett P.O. Box 2121 Corpus Christi, Texas 78403 INP0 Records Center 700 Galleria Parkway Atlanta, Georgia 30339-5957
Houston Lighting & Power Co. Bureau of Radiation Control State of Texas 1100 West 49th Street-Austin, Texas 78756 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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l-COPELAN95-219 PDR
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