ML20149F348

Notice of Violation from Insp on 880104-08.Violation Noted: Procedure 1P0P02-SI-0002,Rev 6,inadequate to Control Alignment of High Head Safety Injection Pumps in Mode 4

ML20149F348
Person / Time
Site:	South Texas
Issue date:	02/10/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20149F344	List: IR 05000498/1988001 ML20149F342 ML20149F348
References
50-498-88-01, 50-498-88-1, NUDOCS 8802170109
Download: ML20149F348 (5)

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APPENDIX B NOTICE OF VIOLATION Houston Lighting & Power Company Docket: 50-498 South Texas Project, Unit 1 Operating License: NPF-71 1

During an NRC inspection conducted on January 4-8, 1988, violations of NRC requirements were identified. The violations involved the lineup' of the high head safety injection pump controls, temporary modifications, locked valves, post haintenance testing, surveillance procedures discrepancies, implementation of surveillance test requirements, overdue station problem report investigations, and inadequate corrective action. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR '

Part 2, Appendix C (1988), the violations are listed below:

A. High Head Safety Injection pump Controit 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 the emergency core cooling system.

Procedure IPOP02-SI-0002, Revision 6, dated December 30, 1997, Safety Injection System Initial Lineup, nas been established in accordance with 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 this procedure was not adequate to control the alignment of the nigh head safety injection pumps in Mode 4. Forms 3, 7, and 11, providing the Mode 4 alignment of safety injection system Trains A, B, and C, respectively, specified the required position for the high head safety injection pump main control board handswitches to be "PTL" (Pull to Lock). Following this procedure would have made all three high head safety injection pumps inoperable in Mode 4, contrary to Technical Specification 3.5.3.

This is a Severity Level IV violation. (Supplement I)(498/8801-01)

8. Temporary Modifications 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, "Tempo'rary Modifications and Alterations," has been established in accordance with this Technical Specification.

8802170109 900210 PDR ADOCK 05000498 0 DCD

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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 be annotated and clouded in red to idantify 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 modification request.

J Contrary to the above, on January 5,1988, the NRC inspector found that the requirements of Section 4.7 of Procedure OPGP03-ZO-0003 had not been  !

met for Temporary Modification TI-Bl-87-252 for Drawing SR289F05038 in that no markup had been made. '

This is a Severity Level IV violation. (Supplement I)(498/8801-02) i C. Locked Valves -

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 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 this Technical Specification.

Form 9 of this procedure, Initial Lineup Train C, requires Manual Valves SI-0059C, SI-0224C, and 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 locked and that SI-0224C and SI-0070C were 1 closed but inadequately lockad. The cables and padlocks on these latter

] two valves could easily be removed by hand. ,

3 This is a Severity Level IV violation. (Supplement I)(498/8801-03)

D. Containment Intecrity l 1

Technical Specification 3.6.1.1 requires that containment integrity be maintained in Modes 1, 2, 3, and 4. The conditions of license regulation, 10 CFR 50.54 invokes Appendix J to 10 CFR 50 to define containment integrity and to limit combined leakage, measured by test, to le:s than .6 La.

l Contrary to the above, the licensee was in Mode 4 on October 31 and

] November 1, 1987, with Containment Isolation Valve BIRAMOV0003, not tested for local leak rate after maintenance so that the ability meet the .6 La criterion was not determined.

1 This is a Severity Level IV violation. (Supplement I)(498/8801-04)  !

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3 E. Surveillance Procedure Discrepancies Criterion V of 10 CFR 50, Appendix B, requires, in part, that activities affecting quality be performed in accordance with approved drawings, instructions, and procedures appropriate to the activity.

The licensee's approved Operations Quality Assurance Plan, Section 112 "Test Control," Paragraph 6.4 requires that test procedures 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 to provide adequate procedures to control the activities affecting the quality of technical specification .

surveillances as identified in the six examples cited below:

1, In December 1987, the licensee collected 250 milliliter waste liquid discharge samples in lieu of the one liter samples required by Procedure 1 PSP 07-WL-0001.

2. On January 7,1988, it was found that Procedure CPSP07-CR-0002 was inadequate in that it failed to provide the necessary requirement to calculate an average sample. Chemistry Technicians were observed to be calculating the average sampir, in accordance with verbal instructions in lieu of following the procedure.

3. On January 6, 1988, it was found that Procedures 1 PSP 02-RC-0454, 0461, and 0462 had been improperly modified by Field Change Request to waive Steps 7.4.2 and 7.7.16 wher. reactor coolant temperature is below 538'F in that the data sheet was not modified to support the change.

4. On Januar/ 7, 1988, it was found that Procedure OPSPO4-XC-0001, Revision 1, had been improperly revised such that changes were incorporated into an unapproved draft of Revision 0 in lieu of an approved copy of Revision 0, resulting in a Revision I that contained 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 valves of the acceptance criteria due to a series of inappropriate changes. This is contrary to the requirements of OPGP03-ZE-0005, Revision 6. "Plant Surveillance Procedure Preparation," Section 3.2.6.

6. On January 6, 1988, it was found that two completed surveillance test packages for OPSP04-DG-0001 were presented to the Plant Operations Review Committee (PORC) for acceptance of the results based on previously accomplished preoperational test information with missing data. The packages were approved by the PORC with missing dats.

This is a Severity Level IV violation. (Supplement I)(498/8801-05)

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F. _I_mplementation of Technical Specification Requirements l Technical Specification 6.8.1 requires that written procedures shall be  !

established, implemented, and maintained covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Contrary to the e.bove, it was found on January 7,1988, that the licensee had failed to provide test procedures, which completely implemented 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 ,

i had been deleted when the final technical specifications were issued, , ,

2 thus resulting in an incomplete and' inadequate procedure for

conducting the surveillance. t

2. Procedure OPSP10-II-0003 was found to contain an incorrect and 1 nonconservative equation for adjusting the core radial peaking factor l limit for fractional power levels, thus resulting in an incorrect and j inadequate procedure conducting the surveillance.

This is a Severity Level IV violatt.w., (Supplement I)(498/8801-06) .[

i G. Overdue Station Problem Report Investigation Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved *

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1 quality assurance plan require that activities affecting quality be  !

4 conducted in accordance with approved procedures. Interdepartmental -

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Procedure IP 1.450, "Station Problem Reporting," requires that corrective  !

! investigations be completed within 17 days. t a

Contrary to the above, on January 4, 1988, 68 of 204 station problem '

reports were overdue (past 17 days) for completion.

4 This is a Severity L9 vel IV violation, (Supplement I)(498/8801-07)

) H. Inadequate Corrective Action i  !

4 Criterion XVI of Appendix B to 10 CFR Part 50 and the licensee's approved j quality assurano plan require conditions adverse to quality be promptly identified and corrected. In August 1987, a quality assurance audit ,

i deficiency report was issued which identified 55 of 179 station problem i reports were overdue for completion. The deficiency was closed on the '

basis thr.t tracking responsibility for station problem report investigation tracking was procedurally changed. l Contrary to the above, it was found on January 4,1988, that the -

J corrective action was not ad1quate in that 68 of 204 station problem j j reports were overdue for completion. '

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This is a Severity Level IV violation. (Supplement I)(498/8801-08) f l

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Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to this Office within 30 days of the date of the letter transmitting this Notice.- This reply, should include for each violation: (1) the reason for tne violation if admitted, (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. Where good cause is shown, consideration will be given to extending the responde time.

Dated at Arlington, Texas this /ct,A, day of JM.,1988. -

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