ML20149L452
| 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: |
| References | |
| EA-96-044, EA-96-44, NUDOCS 9602260328 | |
| Download: ML20149L452 (7) | |
See also: IR 05000498/1996012
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE, SUITE 400
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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
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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control rods each indicating six steps withdrawn, all control rods had fully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
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operating procedure.
The second event involved operators erroneously applying
an exception during a surveillance test when a safety-related motor-operated
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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
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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
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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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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~
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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
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severity of the violation, (2) the application of t1e factors that the NRC
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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
deliberations on this matter.
No response regarding the apparent violation is
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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,
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which subsequently, have been found to be contrary to procedural requirements.
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Houston Lighting and Power Company
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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.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
/
s' abf.enb<~
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omas P.
n,4irector
ivision of Reactor Safety
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Dockets:
50-498
50-499
Licenses:
NPF-80
Enclosures:
1.
2.
NRC Inspection Report
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50-498/96-12: 50-499/96-12
w/ attachments
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Houston Lighting and Power Company
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cc w/ enclosures:
Houston Lighting & Power Company
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ATTN:
Lawrence E. Martin. General Manager
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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
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
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Central Power & Light Company
ATTN:
G. E. Vaughn/C. A. Johnson
P.O. Box 289
Mail Code:
N5012
Wadsworth. Texas 77483
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
Office of the Governor
ATTN:
Andy Barrett. Director
Environmental Policy
P.O. Box 12428
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Houston Lighting and Power Company
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Judge. Matagorda County
Matagorda County Courthouse
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1700 Seventh Street
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Bay City. Texas 77414
Licensing Representative
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Houston Lighting & Power Company
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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
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
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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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W. L. Brown. RC
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OE:EA File. MS: 7-H-5
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DOCUMENT NAME:
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To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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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
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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