ML20151A315
| ML20151A315 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/08/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151A304 | List: |
| References | |
| 50-498-88-11, NUDOCS 8807190329 | |
| Download: ML20151A315 (3) | |
Text
-,
APPENDIX NOTICE OF VIOLATION Houston Lighting & Power Company Docket:
50-498 South Texas Project, Unit 1 Operating License: NPF-76 During NRC inspections conducted February 11 through March 31 and April 5 through May 2,1988, four violations of NRC requirements were identified. The
. violations involved unrelated incidents of operating the plant in conditions prohibited by Technical Specifications.
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.1. Technical Specification (TS) Section 6.0 (Administrative Controls),
Specification 6.8.1, requires that procedures shall be established, implemented, and maintained.for plant operations.
Plant Procedure 1 PEP 04-ZX-0004, Revision 3, "Isothermal Temperature Coefficient (ITC)
Measurement," requires the test data taken to be reviewed and signed off by an independent reviewer.
Contrary to the above, the NRC identified an error during a test results verification. During the week of March 8, 1988, the test was performed and incorrect data for the ITC was obtained due to an error in transferring the information from the test graph to the data sheet.
This led to an erroneous calculated value for the moderator temperature coefficient. This data was signed off as reviewed by an engineer. The test director, engineering manager, plant manager, and Plant Operations Review Committee (PORC) also approved the test results. The NRC inspector identified the error during a test results verification.
(NRCInspection Report 50-498/88-24, paragraph 3c)
This is a Severity Level IV violation.
(Supplement I)(498/8824-02)
A.2. The TS Section 6.0 (Administrative Controls), Specification 6.8.1.,
requires that written procedures shall be established, implemented, and maintained for plant operations.
Plant Procedure OPOP01-ZQ-0030, Revision 3, "Maintenance of Plant Operations Log Book," Step 6.2.3.15, requires entries into the control room log book of the cause of any abnormal occurrence and corrective action taken.
Further, Addendum 3 of Plant Procedure 1 PEP 04-ZA-0001, Revision 3, "Initial Starting Test Program Sequence and Administration," Item 4, requires equipment problems and corrective actions associated with the test be documented in the Chronological Test Log.
Contrary to the above, on March 8,1988, the "A" train PORV stuck open; a failure that could have had a potential impact on the Startup Physics Testing that was in progress. The licensee failed to note this equipment failure or corrective action in the Chronological Test Log for 1 PEP 04-ZX-0001 as required by addendum 3 of Plant Procedure IPEP04-ZA-0001, Revision 3, even though the equipment failure was the subject of detailed 8807190329 esoyog PDR ADOCK 05000498 PDC
.I 2
I troubleshooting.
Furthermore, the entry in the control room log was inadequate to satisfy the requirements of Plant Procedure DP0P01-ZQ-0030, Revision 3, Step 6.2.3.15, since the entry did not document the cause of the abnormal occurrence and the corrective action taken by the licensee.
(NRC Inspection Report 50-498/88-24, paragraph 3.a and 3.f)
This is a Severity Level IV violation.
(SupplementI)(498/8824-01)
B.
TS 3.52 requires three operable independent ECCS subsystems. With one ECCS subsystem inoperable, the subsystem must be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant must be shut down in accordance. with the action statement requirements. TS 3.5.2 does not describe actiens for two inoperable ECCS subsystems; therefore, TS 3.0.3 applies. TS 3.0.3 requires that when a limiting condition for operation is not met, except as provided in the associated action requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a mode in which the specification does not apply by placing it in at least Hot Shutdown (Mode 4) within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, on February 13, 1988, at 4:17 a.m., the licensee suspended a cooldown being performed under TS 3.0.3 when maintenance that satisfied an action for TS 3.7.14. was complete on essential chiller C and returned the plant to Hot Standby (Mode 3) without having met the requirements of TS LC0 3.5.2 or its associated action statements in that two Emergency Core Cooling Subsystems A and C were not fully operable.
(NRC Inspection Report 50-498/88-11, paragraph 2.d)
This is a Severity Level IV violation.
(SupplementI)(498/8811-02)
C.
The TS Section 6.0 (Administrative Controls), Specification 6.8.1.,
requires that procedures shall be established, implemented, and maintained for plant operations.
Plant Procedure OPGP03-Z0-0001, Revision 7, "Equipment Clearance,"
describes the requirements for controlling system boundaries and the logging of components within these boundaries. Step 3.1.3.b requires that all valves inside the boundary shall be listed on the clearance and shall be returned to their required operating position prior to releasing boundary valves.
Contrary to the above, Plant Procedure OPGP03-Z0-0001, Revision 7, was not followed in that boundaries were not correctly controlled and the associated valves within the boundaries were not properly listed on the clearance as required in Step 5.1.3.b of the procedure.
Specifically drain valve LV-002L and LU-0119 were opened af ter the boundary was established; however, they were not returned to their required operating position prior to releasing the boundary valves. These failures to follow procedures resulted in approximately 1000 gallons of lubricating oil for the No. 13 Emergency Diesel Generator being pumped from the lube oil sump onto the floor of the diesel generator building.
(NRC Inspection Report 50-498/88-24, paragraph 5)
N This is a Severity Level IV violation. (Supplement I)(498/8824-04)
ot s.
3 Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear-Regulatory Commission, ATTN: Document Control-Desk, Washington, D.C. 20555 with a copy to the Regional Administraton, Region IV, and if applicable, a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice'of Violation" and should include for each violation: (1) the reason for
. the 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.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration will-be given to extending the response time.
f.
Dated at Arlington, Texas, this fB day of 1988.
f i
i l
t 1
I