ML20148M652
| ML20148M652 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/24/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8804060057 | |
| Download: ML20148M652 (2) | |
See also: IR 05000498/1988001
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MAR 2 41988
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In Reply Refer To:
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Dockets:
50-498/88-01
50-499/88-01
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Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P.O. Box 1700
Houston, Texas 77001
Gentlemen:
Thank you for your letter of March 1,1988, in response to our letter and
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Notice of Violation dated February 10, 1988. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Violation. We will
review the implementation of your corrective actions during a future inspection
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to determine that full compliance has been achieved and will be maintained.
Sincerely,
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Original Signed By
A. B. Beach
1h
J. Callan, Director
j. Division of Reactor Projects
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cc:
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Houston Lighting & Power Company
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ATTN:
M. A. McBurnett, Manager
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Operations Support Licensing
P.O. Box 289
Wadsworth, Texas 77483
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Houston Lighting & Power Company
-2-
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cc:
(cont'd)
Houston Lighting & Power Company
ATTN: Gerald E. Vaughn, Vice President
Nuclear Operations
P.O. Box 1700
Houston, Texas 77001
Houston Lighting & Power Company
ATTN:
S. L. Rosen
P.O. Box 289
Wadsworth, Texas 77483
Central Power & Light Company
ATTN:
R. L. Range /R. P. Verret
P.O. Box 2121
Corpus Christi, Texas 78403
City Public Service Board
ATTN:
R. J. Costello/M. T. Hardt
P.O. Box 1771
San Antonio, Texas 78296
City of Austin Electric Utility
ATTN:
R. J. Miner, Chief Operating
Officer
721 Barton Springs Road
Texas Radiation Control Program Director
bec:
bec to DMB (IE01)
bec distrib. by RIV:
RRI-0PS
R. D. Martin, RA
SectionChief(DRP/D)
RPSB-DRSS
MIS System
RIV File
Lisa Shea, RM/ALF
RSTS Operator
R. Bachmann 0GC
D. Hunnicutt
P. Kadambi, NRR Project Manager
D. Powers
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' The Light
company
PO. Bos 1700 Houston, Texas 77001 (713) 228 9211
ilouston Lighting & Power
March 1, 1988
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ST-HL-AE-2541
File No.:
G2.04
U. S. Nuclear Regulatory Comission
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Attention:
Document Control Desk
Washington, DC 20555
South Texas Project Electric Generating Station
Unit 1
Docket No. STN 50-498
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Response to Violatiens 8801-01 through 8801-08
HL&P has reviewed the Notices of Violation included in inapection Report
88-01 and submits the attached responses pursuant to 10CFR Part 2.
If you have any questions, please contact Mr. M. A. McBurnett at
(512)972-8530.
Wy
G. E. Vaughn
Vice President
Nuclear Plant Operations
GEV/WH/kr.
Attachment:
Responses to Notices of Violation
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MAR 2 2
A Subsidiary of Houston Industries' incorporated
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NL.88.053.03
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CT-HL-AE-2541
File No.: G2.04
Page 2
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Regional Administr,ator Region IV
Rufus S. Scott
Nuclear Regulatory Commission
Associate General Counsel
,
611 Ryan Plaza Drive. Suite 1000
Houston Lighting & Power Company
Arlington TX 76011
P. O. Box 1700
Houston. TX 77001
N. Prasad Kadambi. Project Nanager
U. S. Nuclear Regulatory Commission
1 White Flint North
Records Center
11555 Rockville Pike
1100 Circle 75 7'Tkway
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Rockville. MD 20859
Atlanta. Ga. 30339-3064
Dan R. Carpenter
Senior Resident Inspector / Operations
c/o*U. S. Nuclear Regulatory
Commission
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P. O. Box 910
Bay City. TX 77414
J. R. Newman. Esquire
Newman & Holtzinger. P.C.
1615 L Street. N.W.
Washington, DC 20036
R. L. Range /R. P. Verret
Central Power & Light Company
P. O. Box 2121
Corpus Christi. TX 76403
R. John Miner
(2 copies)
Chief Operating Officer
City of Austin Electric Utility
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721 Barton Springs Road
Austin. TX 78704
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R. J. Costello/M. T. Hardt
City Public Service Board
P. O. Box 1771
San Antonio, TX 78296
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Revised 02/03/88
NL.LER. DISTR.1
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Attachment
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ST-HL-AE-2541
Page 1
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A.
Statement of Violation 8801-01:
Hich Head Safety Iniection Pump Controls System Lineup
Technical Specification 6.8.1 requires that written procedures be
established, implemented, and maintained covering the activities
recommended in Appendix A of Regulatory Guide 1.33. Revision 2. February
1978. Section 3 of this appendix recommends procedures for operation of
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the emergency core cooling system.
Procedure IPOP02-SI-0002. Revision 6 dated December 30. 1987 Safety
Injection System Initial Lineup. has been established in accordance with
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Technical Specification 6.8.1 to implement. inter alia. Technical Specification 3.5.3.
Contrary to the above, on January 7. 1988, the NRC inspector found that
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this procedure was not adequate to control the alignment of the high head
saf ety injection pumps in Mode 4.
Forms 3. 7. and 11. providing the
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Mode 4 alignment of saf ety injection system Trains A. B. and C.
respectively, specified the required position for the high head saf ety
injection pump main control board handswitches to be "PTL" (Pull to
Lock).
Following this procedure would have made all three high head
saf ety injection pumps inoperable in Mode 4. contrary to Tectoical
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Specification 3.5.3.
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Reason for violation
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The root cause of this violation was inadequate review of the procedure
to assure its consistency with the requirements of the applicable
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Technical Specifications.
Corrective actions that have been taken:
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Procedure IPOP02-SI-0002 has been revised to correct Forms 3, 7. and
11 to indicate the proper handswitch alignments for all modes.
2.
A review of other system lineup procedures was performed to ensure
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their consistency with the Technical Specifications.
3.
Procedure OPGP03-ZA-0002 has been revised to incorporate requirements
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for an independent technical review of new procedures.
Corrective actions that will be taken:
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No f urther action is required.
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Full Compliance
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The plant is in full compliance.
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AttOchsent
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ST-HL-AE-3541
Page 2
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B.
Statement of Violation 8801-02:
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Temporary Modifi ca ti ons
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Technical Specification 6.8.1 requires that written procedures be
established, implemented, and maintained covering the activities
recommended in Appendix A of Regulatory Guide 1.33. Revision 2.
February 1978.
Procedure OPGP03-ZO-0003. Revision 7. dated September 12. 1987
"Temporary Modifications and Alterations." has been established in
accordance with this Technical Specification.
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Section 4.7 of this procedure requires that the control room hard copy of
piping and instrumentation drawings affected by a temporary modification
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be annotated and clouded in red to identify the existence of a temporary
modification.
It further requires that a copy of the temporary
modification request be attached to the drawing and a notation of which
drawings were updated to be made on the original of the temporary
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modification request.
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Contrary to the above, on January 5, 1988. the NRC inspector found that
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the requirements of Section 4.7 of Procedure OPGP03-ZO-0003 had not been
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met f or Temporary Modification TI-EV-87-252 f or Drawing 5R289F05038 in
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that no markup had been made.
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Reason for violationt
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The root cause of this violation was the Systems Engineer's lack of
attention to detail in following the procedure. A contributing factor
was a lack of positive controls (e.g., signature verifications) on the
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Temporary Modification Request (THR) form to ensure compliance with the
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procedure. Another contributing factor was a lack of clarity in the
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procedure with regard to the treatment of blank and blind flanges.
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Corrective actions that have been takent
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1.
Drawing 5R289F05038 was updated in compliance with procedure
OPGP03-ZO-0003 (i.e., red lining of drawing, attaching a copy of the
TMR. noting drawing update)
2.
A review of outstanding temporary modifications was performed against
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the requirenehts of the procedure.
Identified discrepancies were
corrected.
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ST-HL-AE-2541
Page 3
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3.
Procedure OPGP03-ZO-0003. Temporary Modifications and Alterations,
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was revised to clarify treatment of blank and blind flanges. The
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procedure was also revised to implement the following additional
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controls:
Identification of Key Drawings on the' Temporary Modification
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Request.
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b.
Addition of a confirmation signature indicating that the affected
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drawing (s) have been red lined.
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Addition of a restoration signature indicating that the drawings
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have been restored to normal after temporary modification is
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removed.
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System Engineers have been formally advised of the procedural changes
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and the requirement to follow them in detail.
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Corrective action that will be taken
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No further action is required.
Full Compliance
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The plant is in full compliance.
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ST-HL-AE-2541
Page 4
C.
Statement of Violatior 8801-03:
Locked Valves
Technical Specification 6.8.1 requires that written procedures be
established, implemented, and maintained covering the activities
recommended in Appendix A of gegulatory Guide 1.33. Revision 2.
February 1978. Section 3 of this appendix recommends procedures for
operation of the emergency core cooling system.
Procedure 1 POP 02-SI-0002. Revision 6. dated December 30, 1987 "Safety
Injection System Initial Lineup." has been established in accordance with
this Technical Specification.
Form 9 of this procedure. Initial Lineup Train C. requires Manual Valves
SI-0059C. SI-0224C. ar.d SI-0070C to be locked closed.
Contrary to the above on January 6. 1988, the NRC inspectors found that
SI-0059C was closed, but not locted and that SI-0224C and SI-0070C were
closed but inadequately locked. The cables and padlocks on these latter
two valves could easily be removed by hand.
Reason for violation:
The root cause of the violation was lack of attention to detail on the
part of operations personnel who inspect valves in accordance with the
Locked Valve Program in that inadequately locked and/or unlocked valves
were not identified and corrected in accordance with the Locked Valve
Program OPGP03-20-0027.
Corrective actions that have been taken:
1.
Valves SI-0070C and SI-0224C were locked and valve SI-0059C was
tagged as allowed by procedure.
2.
valves required to be locked in accordance with the Locked Valve
Program were inspected for proper position and locking devices or
administrative controls. None were found to be improperly
positioned. Those that were found to be inadequately locked were
either properly locked or administrative controls were implemented
through the station clearance process.
Corrective actions which will be taken
No further action is required.
Full Compliance
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The plant is in full compliance.
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NL.88.053.03
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AttCchment
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ST-HL-AE-2541
Page 5
D.
Statement of Violation 8801-04:
Containment Intecrity
Technical Specification 3.6.1.1 requires that containment integrity be
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maintained in Modes 1. 2. 3. and 4.
The conditions of license
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regulation. 10CTR50.54 invokes Appendix J to 10 CTR 50 to define
containment integrity and to limit combined leakage measured by test, to
less than 0.6 La.
Contrary to the above the licensee was in Mode 4 on October 31 and
Fovember 1. 1987. With Containment Isolation Valve BIRAMOV0003. not
tested for local leak rate after maintenance so that the ability to moet
the 0.6 La criterion was not determined.
Reason for violation:
The root causes of the event were determined to be:
1.
Failure to provide maintenance planners and maintenance supervisors
with adequate training concerning post maintenance testing (PMT)
requirements regarding containment integrity.
2.
Failure to identify the appropriate PMT requirements f or local leak
rate testing on the MVR during supervisory review.
Corrective actions that have been taken:
1.
A Local Leak Rate Test was satisf actorily performed on the subject
valve and it was returned to an operable status at approximately 2200
hours on January 6. 1988.
2.
A review c,' MVRs and LLRT records was conducted to ensure that proper
testing had been done to assure containment integrity.
3.
Informatica regarding this event was discussed with maintenance
supervisory personnel and maintenance planners. The intent of these
briefinjs was to make these personnel aware of the importance of
maintaining containment integrity. Maintenance planners were advised
to discuss PMT requirements with the cognizant system engineer prior
to issuang a MWR. especially in regards to containment isolation
valves.
4.
To enhance the current MVR program. NWR procedure. OPGP03-ZM-0003.
was revised to assure that the required PMTs are identified on MVRs
involving containment isolation valves.
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NL.88.053.03
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Attachment
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ST-HL-AE-2541
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Page 6
Corrective action that will be takent
Training of shift supervisors and support personnel will be conducted to
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reinforce the importance of post-maintenance testing with regard to
containment integrity requirements.
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Full Compliance
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The plant will be in full compliance upon completion of the training.
This is expected to be done by March 3 1988.
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ST-HL-AE-2541
Page 7
E.
Statement of Violation 8801-05:
Surveillance Procedure Discrepancies
Criterion V of 10 CTR 50. Appendix B. requires, in part, that activities
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'affecting quality be performed in accordance with approved drawings,
insttuctions, and procedures appropriate to the activity.
The licensee's approved Operations Quality Assurance Plan. Section 112.
"Test Control." Paragraph 6.4 requires that test procedure shall provide
instructions for performing tests and provisions for documenting results.
Contrary to the above, the licensee failed to follow procedures
associated with the Surveillance Program and/or failed tp provide
adequate procedure to control the activities affecting the quality of
Technical Specification surveillance as identified in the six examples
cited below:
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1.
In December 1987
the licensee collected 250 milliliter waste liquid
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discharge samples in lieu of the one liter samples required by
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Procedure 1 PSP 07-WL-0001.
2.
On January 7. 1988, it was f ound that Procedure OPSP07-CR-0002 was
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inadequate in that it failed to provide the necessary requirement to
calculate an average sample.
Chemistry Technicians were observed to
be calculating the average sample in accordance with verbal
instructions in lieu of following the procedure.
3.
On January 6. 1988, it was found the Procedures 1 PSP 02-RC-0454. 0461.
and 0462 had been improperly modified by Field Change Request to
waive Stegs 7.4.2 and 7.7.16 when reactor coolant temperature is
below 538 F in that the data sheet was not modified to support the
change.
4.
On January 7, 1988, it was found that Procedure OPSPO4-XC-0001
Revision 1. had been improperly revised such that changes were
incorporated into an unapproved draf t of Revision 0 in lieu of an
approved copy of Revision O. resulting in a Revision 1 that contained
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draft errors. This is contrary to the requirements of
OPGP03-ZA-0002. Revision 10. "Plant Procedures."
5.
On January 6 1988, it was found that Procedure 1 PSP 11-RH-0004
Revision 1. failed to contain numeric values of the acceptance
criteria due to a series _of inappropriate char.ges. This is contrary
to the requirements of OPGP03-ZE-0005. Revision 6. "Plant
Surveillance Procedure Preparation." Section 3.2.6.
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6.
On January 6 1988, it was found that two completed surveillance test
packages for OPSPO4-DG-0001 were presented to the Plant Operations
Review Committee (PORC) for acceptance of the results based on
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previously accomplished preoperational test information with missing
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data. 7he packages were approved by the PORC with missing data.
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ST-HL-AE-2541
Page 8
Reason for violationt
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Item I was attributable to poor judgement by technicians who decided to
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substitute a different size container for the size specified in the
procedure.
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Item 2 was attributable to inadequate description rf required
calculations in the procedure.
Items 3. 4. and $ were attributable to a f ailure to follow procedures
regarding the use of FCRs.
Item 6 is attributable to two factorst
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1.
Personnel reviewing the pre-operational test package prior to its
presentation to PORC failed to detect a copying error.
2.
The level of review performed by PORC vas not of sufficient detail
and depth to detect the copying error.
Corrective actions that have been takent
Item 1:
Chemical Analysis personnel have been reinstructed regarding
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the importance of f ollowing procedures verbatim.
Item 2:
Chemical Analysis surveillance procedures requiring
calculations have been reviewed and revised as necessary to
ensure that adequate instruction on performance of the
calculations is provided.
Items 3-5
A Departmental bulletin was issued providing additional
guidance to NPOD personnel regarding the control of Field
Change Request changes to surveillance procedures.
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Procedure OPGPO3-ZA-OOO2 "Plant _ Procedures" was revised to
include specific guidelines for the review and implementation
of Field Change Requests.
Item 6:
The data missing from the subject packages was reviewed and
approved by PORC and inserted in the file packages,
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An ISEG special investigation was conducted to review the PORC
process to recommend possible enhancemente. The
recommendations, which wele issued February 22. 1988 include
more formal control of the PORC meetings, more control of
"walk-on" items, better definition of s: ope of review.
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Attcchment
ST-HL-AE-2541
Page 9
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Corrective action that will be takent
Management will review the ISEG recommendations and identify any
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improvements and a schedule for implementation by March 31, 1988.
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Full Compliance
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The plant is in full compliance, however, enhancements to the PORC
process may be made following review and analysis of the ISEG report.
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ST-HL-AE-2541
Page 10
F.
Statement of Violation 8801-06:
Implementation of Technical Specification Eeauirements
Technical Specification 6.8.1 requires that written procedures shall be
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established, implemented, and maintained covering activities recommended
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in Appendix A of Regulatory Guide 1.33. Revision 2. February 1978.
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Contrary to the above, it was found on January 7.1988, that the licensee
had failed to provide test procedures, which completely implemerted the
final technical specifications as cited below:
1.
Procedure 1 PSP 10-RC-0001. Revision 0, contained an acceptance
criterion calling for a figure in the technical specifications which
had been deleted when the final technical specifications were issued.
thus resulting in an incomplete and inadequate procedure for
conducting the surveillance.
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2.
Procedure OPSP10-II-0003 was found to contain an incorrect and
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nonconservative equation for adjusting the core radial peaking factor
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limit f or f ractional power levels, thus resulting in an incorrect and
inadequate procedure conducting the surveillance.
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Reason for violations
The root cause of this violation was that the process to incorporate
changes in the T9chnical Specifications into procedures did not track
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required actions to completion.
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Corrective actions that have been takent
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1.
OPSP10-II-0003 has been corrected to be consistent with the .4chnical
Specifications. Procedure 1 PEPO 4-ZG-0007 has been identified as the
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proper procedure for use in RCS flow measurement in lieu of
IPSP10-RC-0001.
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2.
Suf ficient review of surveillance procedures has been completed to
assure compliance with Technical Spec 2fication requirements for
operation through Mode 2.
3.
Procedure OPGP03-ZA-0002 has been revised to require an independent
techn* cal review of new procedures. Requirements have beeb added to
the procedure to perform a "walk through" of new surveillence
procedures to confirm the Frecedure can be accomplished as written.
Additional procedure review criteria have been imposed by means of an
uttribute check sheet which includes items for confirming Technical
Specification requirements.
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4.
Interdepartmental procedure 3.20Q is now in ef f ect which requires
Technical Specification changes to be tracked f rom request through
implementation. It also requires a QA verification of implementation.
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NL.88.053.03
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ST-ML-AE-2541
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Corrective action that will be taken
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Suf ficient review of surveillance procedures to assure that Mode 1
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Technical Specification rrquirements are incorporated will be completed
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prior to exceeding % power.
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rull Compliance
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The plant is in compliance f or operation through Mode 2.
Confirmation of
full compliance will be achieved upon completion of the remaining reviews
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as described above.
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Attcchment
ST-HL-AE-2541
Page 12
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G.
Statement of Violation 8801-07:
Overdue Station Problem Report Investigation
Criterion V of Appendix B to 10 CPR Part 50 and the licensee's approved
quality assurance plan require that activities affecting quality be
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conducted in accordance with approved procedures.
Interdepartmental
Procedure IP 1.45Q. "Station Problem Reporting." requires that corrective
investigations be completed within 17 days.
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Contrary to the above, on January 4 1988. 68 of 204 station problem
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reports were overdue (past 17 days) for completion.
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Reason for the violationt
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The root cause of the violation was inadequate assignment of resources to
prioritize and resolve the SPRs.
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Corrective actions that have been taken
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1.
The safety significance of each SPR is evaluated when the SPR is
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first initiated, and immediate action is taken if required to assure
plant safety. A review was performed which confirmed that the
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conditions described in the open SPRs have been adequately addressed
so that plant saf ety is not adversely af fected.
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2.
Revision 1 of Procedure 1.450 was implemented on February 22, 1988.
This new procedure increased management's involvement in the process
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by requiring an early establishment of priority and due date by the
Plant Manager. The revision also requires the SPR originator to take
the SPR directly to the Shif t Supervisor.
3. . Additional licensing engineers have been assigned to coordinate
resolution of SPRs. These personnel have participated in a concerted
effort to resolve overdue SPRs. The backlog of overdue SPRs has been
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reduced to an acceptable level.
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Correction action that will be tatent
No further action is required.
Full Compliance:
The plant is in full compliance.
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NL.88.053.03
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Attcchtsnt
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ST-HL-AE-2541
Page 13
H.
Inadecuate corrective Action (8801-08):
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Criterion XVI of Appendix B to 10 CFR Part 50 and the licensee's approved
quality assurance plan require conditions adverse to quality be proeptly
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identified and corrected.
In August 1987, a quality assurance audit
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deficiency' report was issued wh4ch identified 55 of 179 station problem
reports were overdue for completion. The deficiency was closed on the
basis that tracking responsibility for station problem report
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investigation tracking was procedurally changed.
Contrary to the above, it was found on January 4, 1986, that the
corrective action was not adequate in that 68 of 204 station problem
reports were overdue for completion.
,
Reason for the violation:
As noted in the statement of the violation, the backlog of overdue SPRs
was identified in an audit in August 1987, and as corrective action
procedures were changed to assign responsibility for coordination of SPRs
to Licensing. Nuclear Assurance accepted this response and a follow up
audit to determine the effectiveness of the corrective action was
scheduled for February 1988. Prior to the follow-up audit, management
failed to identify that the corrective action had not been effective.
Corrective actions which have been taken:
In accordance with the schedule adopted upon acceptance of the response
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to the August 1987 audit, in February 1988 Nuclear Assurance completed
its follow-up audit of the effectiveness of the ccrrective actions. The
follow-up audit identified inadequate effectivenesr, of the earlier
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corrective action as a significant deficiency (DR S87-064. Rev.1).
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Response to DR 587-064. Rev. 1 is due by March 18. 1988. The response to
DR S87-064. Rev. I will be reviewed by Nuclear Assurance.
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The corrective actions described in response to Notice of Violation
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88 01-07 have been implemented. and are expected to resolve DR S87-064.
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Rev. 1.
As an interim measure, until management gains added confidence
in the effectiveness of the revisions to the SPR program. Licensing is
providing management with weekly reports of SPR status.
Corrective actions that will be taken:
As a result of the DR. a review of Station Problem Reports is being
conducted to assure that root causes were adequately addressed and that
supporting documentation properly dispositions the required actions.
This activity is expected to be complete by 60 days after the issuance of
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the Full Power operating License.
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Full Compliance:
The plant will be confirmed to be f ull compliance utan completion of the
SPR review described above.
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NL.88.053.03
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