ML20149L452

Forwards Insp Repts 50-498/96-12 & 50-499/96-12 on 960108-22 & Notice of Violation

ML20149L452
Person / Time
Site:	South Texas
Issue date:	02/20/1996
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
Shared Package
ML20149L454	List: IR 05000498/1996012 ML20149L452 ML20149L456
References
EA-96-044, EA-96-44, NUDOCS 9602260328
Download: ML20149L452 (7)

See also: IR 05000498/1996012

Text

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t P"%g UNITED STATES

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fg NUCLEAR REGULATORY COMMISSION

, y g REGION IV

% # 611 RYAN PLAZA DRIVE, SUITE 400

%, AR LINGTON. TEXAS 76011-8064

February 20, 1996

Houston Lighting & Power Company

ATIN: William T. Cottle, Group

Vice President, Nuclear

P.O. Box 289

Wadsworth Texas 77483

SUBJECT: NRC INSPECTION REPORT 50-498/96-12: 50-499/96-12 AND NOTICE OF

VIOLATION

This refers to the special inspection conducted by Mr. S. McCrory and others

of this office, on January 8-22, 1996, at the South Texas Project Electric

Generating Station, Units 1 and 2, facility. The purpose of the inspection

was to determine whether activities authorized by the license were conducted

safely and in accordance with NRC requirements. At the conclusion of the

inspection, the findings were discussed with you and those members of your

staff identified in the enclosed report.

Areas examined during the inspection are identified in the report. Within

these areas, the inspection consisted of selective examinations of procedures l

and representative records, interviews with personnel, and observation of

activities in progress. The inspection focused on an unresolved item

addressed in NRC Inspection Report 50-498/95-29: 50-499/95-29. The unresolved

item was related to two events wherein procedural non-adherence was exhibited.

The first event involved the decision of the operators that, even~ with three

control rods each indicating six steps withdrawn, all control rods had fully

inserted following the reactor trip on December 18, 1995. Therefore, the

operators did not initiate emergency boration as required by the emergency l

operating procedure. The second event involved operators erroneously applying  ;

an exception during a surveillance test when a safety-related motor-operated j

valve malfunctioned on December 23, 1995. )

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Based on the results of this inspection, the NRC has determined that, with

respect to the first event dealing with the reactor trip, one apparent 4

violation was identified and is being considered for escalated enforcement

action in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy) (60 FR 34381: June 30, 1995).

Accordingly, no Notice of Violation is presently being issued for these

inspection findings. In addition, please be advised that the number and ,

characterization of apparent violations described in the enclosed inspection

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report may change as a result of further NRC review.

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Houston Lighting and Power Company -2-

We are particularly concerned by the failure of operators to emergency borate

while instruments indicated that three control rods had not fully inserted

following a reactor trip. This behavior is contrary to our expectation that~ -

operators at the South Texas Project would act conservatively when faced with

unexpected plant conditions. Our inspection results indicate that the

operators did not accept the rod position indication as valid although we

-found no basis to question the indication. The operators stopped to question

and interpret the emergency operating procedures during the initial response

stage critical to achieving a safe shutdown condition. Our inspection

determined that this was contrary to the training which operators have

received. Management's initial review of this event did not address the

operator response to the event. Our concern is broadened by several

violations identified during the past year (cited and non-cited) that appear

to have a common element of operator performance.

A predecisional enforcement conference to discuss this apparent violation has

been scheduled for March 6.1996. The decision to hold a predecisional

enforcement conference does not mean that the NRC has determined that a

violation has occurred or that enforcement action will be taken. This

conference is being held to obtain information to enable the NRC to make an

enforcement decision, such as a common understanding of the facts, root

causes, missed opportunities to identify the apparent violation sooner,

corrective actions, significance of the issues and the need for lasting and

effective corrective action. In particular, your discussion should include

consideration of the concern discussed above, In addition, this is an

opportunity for you to point out any errors in our inspection report and for

you to provide any information concerning your persaectives on: (1) the ,

severity of the violation, (2) the application of t1e factors that the NRC l

considers when it determines the amount of a civil penalty that may be

assessed in accordance with Section VI.B.2 of the Enforcement Policy, and

(3) any other application of the Enforcement Policy to this case, including

the exercise of discretion in accordance with Section VII,

You will be advised by separate correspondence of the results of our i

deliberations on this matter. No response regarding the apparent violation is 1

required at this time,

With respect to the second event dealing with the surveillance test, one

violation of NRC requirements occurred. The violation is cited in the

enclosed Notice of Violation (Notice) and the circumstances surrounding it are

described in detail in the subject ins)ection report. The violation is of

concern because it was identified by t1e NRC and it appears to have arisen

from an operating philosophy supporting independent interpretation of

arocedural requirements by operators on shift. This observation is borne out  ;

ay the fact that management initially supported the actions of operators, l

which subsequently, have been found to be contrary to procedural requirements.

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Houston Lighting and Power Company -3-

You are required to respond to this letter and should follow the instructions

specifled in the enclosed Notice when preparing your response. In your

response, you should document the specific actions taken and any additional

actions you plan to 3revent recurrence. Your response may reference or

include previous doc <eted correspondence, if the correspondence adequately

addresses the required response. After reviewing your response to this

Notice. including your proposed corrective actions and the results of future

inspections, the NRC will determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

Finally, we would like to direct your attention to a concern regarding an

impact created by the auxiliary feedwater system on initial response to

emergency conditions contained in Section 1.5 of the attached inspection

report,

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of

this letter, its enclosure (s), and your response will be placed in the NRC

Public Document Room (PDR). To the extent possible, your response should not

include any personal, privacy. ]roprietary, or safeguards information so that

it can be placed in the POR witlout redaction.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance 3rocedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980. Pub. L. No. 96.511.

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Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

/ _

s' abf.enb<~

omas P.

/

n,4irector

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ivision of Reactor Safety

Dockets: 50-498

50-499

Licenses: NPF-76

NPF-80

Enclosures:

1. Notice of Violation

2. NRC Inspection Report

i 50-498/96-12: 50-499/96-12

, w/ attachments

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Houston Lighting and Power Company -4-

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cc w/ enclosures:

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Houston Lighting & Power Company

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ATTN: Lawrence E. Martin. General Manager

Nuclear Assurance & Licensing

P.O. Box 289

Wadsworth. Texas 77483

City of Austin

Electric Utility Department

AiTN: 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

Morgan Lewis & Bockius

ATTN: Jack R. Newman. Esq.

1800 M. Street. N.W.

Washington. D.C. 20036-5869

,

Central Power & Light Company

ATTN: G. E. Vaughn/C. A. Johnson

P.O. Box 289

Mail Code: N5012

Wadsworth. Texas 77483

INPO

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

Office of the Governor

ATTN: Andy Barrett. Director

Environmental Policy

P.O. Box 12428

Austin. Texas 78711

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Houston Lighting and Power Company -S-

Judge. Matagorda County

Matagorda County Courthouse

l 1700 Seventh Street

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Bay City. Texas 77414

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Licensing Representative l

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Houston Lighting & Power Company '

Suite 610

Three Metro Center

Bethesda. Maryland 20814 i

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Houston Lighting & Power Company l

ATTN: Rufus S. Scott, Associate I

General Counsel

P.O. Box 61867

Houston. Texas 77208

Egan & Associates. P.C.

ATTN: Joseph R. Egan. Esq.

2300 N Street N.W.

Washington, D.C. 20037

Little Harbor Consultants. Inc

ATTN: Mr. J. W. Beck

44 Nichols Road

Cohasset. MA 02025-1166

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Houston Lighting & Power Company -6-

E-Mail report to D. Nelson (DJN)

E-Mail report to NRR Event Tracking System (IPAS)

bcc to DMB (IE01)

bcc distrib. by RIV:

L. J. Callan Resident Inspector

Branch Chief (DRP/A) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

MIS System DRS-PSB

RIV File Project Engineer (DRP/A)

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R. Bachmann. OGC (MS: 15-B-18) Branch Chief (DRP/TSS)

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G. F. Sanborn. E0 W. L. Brown. RC

OE:EA File. MS: 7-H-5

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DOCUMENT NAME: R:\ST612RP.SLM

To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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E-Mail report to D. Nelson (DJN)

E-Mail report to NRR Event Tracking System.(IPAS)

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DMB1(IE01);

bcc distrib. by RIV:

L. J. Callan Resident Inspector

Branch Chief (DRP/A) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

MIS System DRS-PSB

RIV File Project Engineer (DRP/A)

R. Bachr;driri, OGC (MS: 15-B-18) Branch Chief (DRP/TSS)

G. F. Sanborn. E0 W. L. Brown, RC

OE:EA File, MS: 7-H-5

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DOCUMENT NAME: R:\ST612RP.SLM

To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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