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Ack Receipt of Re Violations Noted in Insp Repts 50-498/88-24,50-498/88-11 & 50-499/88-11
	ML20154K368
Person / Time
Site:	South Texas
Issue date:	09/19/1988
From:	Callan L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J; HOUSTON LIGHTING & POWER CO.
References
	NUDOCS 8809230298
	Download: ML20154K368 (2)
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In Reply Refer To: 9 l$ g

Dockets: 50-498/88-24

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50-498/88-11

50-499/88-11

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7 Houston Lighting & oower Company

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ATTN: J. H. Goldberg, Group Vice '

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President. Nuclear

P.O. Box 1700 ,

Houston, Texas 77001

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Gentlemen:

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Thank you for your letter dated August 3,1988, in response to our j

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letter dated July 8,1988. We have no further questions at this time and will ,

review your corrective action during a future inspection.

Sincerely,

Onkinal Styned Bp i

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A.B. BEACH

! L. J. Callan Director ,

Division of Reactor Projects i

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Houston Lighting & Power Company Newman & Holtzinger, P.C.

ATTN: M. A. McBurnett, Manager ATTN: J. R. Newman, Esquire ;

) Operations Support Licensing 1615 L Street, N.W. i

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P.O. Box 289 Washiagton, D.C. 20036

Wadtworth, Texas 77483 ;

Houston Lighting & Power Company Houston Lighting & Power Company i

ATTN: Gerald E. Vaughn, Vice President ATTN: S. L. Ro.an

Nuclear Operations P.O. Box 289 ;

P.O. Box 289 Wadsworth, Texas 77483

Wadsworth Texas 77483

Houston Lighting & Power Company Houston Lighting & Power Company !"

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ATTN J. T. Westermeier, rieneral Manager ATTN: R. W. Chewning, Chairman .

Nuclear Safety Review Board

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South Texas Project ;

P.O. Box 289 P.O. Box 289 l

Wadsworth, Texas 77483 Wadsworth, Texas 77483 j

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Houston Lighting & Power Company -2-

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Central Power & Light Company City Public Service Board *

ATTN: R. L. Range /R. P. Verret ATTN: R. J. Costello/M. T. Hardt

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P.O. Box 2121 P.O. Box 1771

Corpus Christi, Texas 78403 San Antonio, Texas 78296 l

City of Austin Electric Utility Houston Lighting & Power Company l

ATTN: R. J. Miner, Chief Operating ATTN: Licensing Representative !

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Officer Suite 610 l

721 Barton Springs Roed Three Metro Center

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Austin, Texas 78704 Bethesda, Maryland 20814 l

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Texas Radiation Control Program Director

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bec to DNS (IE01)

bec distrib. by RIV:

DRP RRI-OPS :

R. D. Martin, RA DRS

SectionChief(DRP/D) RPB-DRSS j

MIS System RIV File ,

Lisa Shea, RM/ALF RSTS Operator

R. Bachmann, 0GC G. Dick, NRR Project Manager

Project Engineer, DRP/D RRI-CONST ;

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The Light

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company PO. Box 1700 Houston, Texas 77001 (713) 228 9211

Houston Lighting & Power ,

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August 3, 1988 -

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10CFR2.201 / i

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U. S. Nuclear Regulatory Ceraission _

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Attention: Documer.: Control Desk

Washington, DC 20555

South Texas Proj ect Electric Ger,trating Station

Unit 1

Docket No. STN 50 98

Response to Severity Level IV Violations

Resultine frem the NRC Enfercement Conference Held May 26, 1988

Houston Lighting & Power has reviewed Notices of Violation 8811-02,

8824-02, and 8824-04 and submits the attached responses pursuant to

, 10CFR2.201. Our response to violation 8824-01 vill be submitted by separato

correspondence.

The response provided to Notice of Violation 8811 02 was previously

submitted to the NRC by Licensee Event Report 88-019 dated March 14, 1988.

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'le have been informed by NRC Region IV inspection personnel that thic Licensee

Event Rsport vill be closed in upcoming Inspection Report 88-039.

If you should have any questions on this matter, please contact

Mr. M. A. McBurnett at (512) 972-8530.

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G. E. Vaughn

Vice President

Nuclear Plant Oper tions

GEV/RAF/n1

Attachment: Response to Notices of Violation

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1" .88.200.01 A Subsidiary of Houston Industries incorporated

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.itouston Lighting & Power Company

ST-HL-AE-2741

File No.: G2.04

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Regional Administrator, Region IV Rufus S. Scott

Nuclear Regulatory Commission Associated General Counsel

611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Compan*/

Arlington, TX 76011 *

. P. O. Box 1700

Houston, TX 77001

George Dick

U. S. Nuclear Regulatory Commission INFO

Vashington, DC 20555 Fecords Center

1100 Circle 75 Parkvay

Jack E. 3ess Atlanta, Ga. 30339-3064

Resident Inspector / Operations

e/o U. S. Nuclear Regulatory Commission Dr. Joseph H. Hendrie

P. O. Box 910 50 Be11 port Lane

Bay City, TX 77414 Be11 port, NY 11713

Don L. Garrison 1

Resident Inspector / Construction

c/o U. S. Nuclear Regulatory Commission

T. O. Box 910

Bay City, TX 77414

J. R. Newman, Esquire

Newman & Holtzin6er, P.C.

1615 L Street, N.V.

Washington, DC 20036

R. L. Rat.ge/R. P. Verret

Central Power & Light Comptny

P. O. Box 2121

Corpus Christi, TX 78403

R. John Miner (2 copies) ,

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Chief Operating Officer

City of Austin Electric Utility ,

1 721 Barton Springs Road

Austin, TX 78704

R. J. Costello/M. T. Hardt

City Public Service Board

P. O. Box 1771

San Antonio, TX 78296

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12Rcvised 06/16/88

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South 72xas Project Electric Generating Statien

Unit 1

Docket No STN 50-498

Response to Notice of Violation 8811-02

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I Statement of Violation

TS 3.52 (sic] requires three operable independent ECCS subsystems. With

can ECCS subsystem inoperable, the subsystem must be restored within 72

hours or the plant must be shut down in accordance with the action

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statement requirements. TS 3.5.2 does not describe actions for two

inoperable ICCS 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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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. vas complete on essential

chiller C and returned the plant to Hot Standby (MLde 3) without having

met the requirements of TS LCO 3.5.2 or its associated action statements

in that two Emergency Core Cooling 3ubsystems A and C sere not fully

eperabla.

II Housten Liehting & Power Positlen _

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Houston Lighting & Power does '4ct contest the violation.

' Please note that in the Statement of viola' ion in your letter dated

July 8, 1988 tha reference to T.S. 3.52 should be 3.5.2. t

III Reason for Violation

The cause of this violation was a personne'. error. The Operability

Tracking Log was incorrectly v.pdated and maintained with regard to

af fected ESF equipment when Trcin A Essential Chiller was Jac1. red

inoperable.

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Attachment

ST-HL-AE-2741

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IV Corrective Actions Taken and Results Achieved

A. Special training has been conducted, emphasizing the importance of

accurately determining the subsystems affected by inoperable

components.

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B. Training on the use of the "Hypothetical Mode" of the coeputarized

LCO Tracking System has been provided to the shift supervisors to

enhance their understanding of the impact of inoperable equipment on

other systems.

V Corrective Actions Taken to Prevent Recurrence

Procedure OPOP01-2Q-0030, Maintenance of Plant Opersticas Logbooks, has

been revised to provide a more structured Technical Specification review

for impact of inoperable equipment on other systems. This review

requires the shift and unit supervisors and shift technical advisors to

independently evaluate affected equipment.

VI Full Comp 1fanee

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The plant is in full compliance at this time.

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fouston Lighting & Power Company

Attachment

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Page 1 of 3

South Texas Project Electric Generating Station

Unit 1

Docket No STN 50-498

Response to Notiew of Violation 8824-02

I Statement of violation

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

IPEP04-ZX-0004, Revision 3. "Isothemal Temperature Coef ficient (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 incorrset 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 reviev6d 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.

II Houston Liehtine & Power Position

Houston Lighting & Power does not contest the violatius.

III Reason for Violation

The violation occurred as a result of personnel error during the conduct

of the test and inadequate review during the post test review and

approval phase.

The personnel who were conducting the Asethermal temperature coefficient

measurements are degreed nuclear engineers, certified Test Directort,

and are licensed Senior Reactor Operators. .he two indt?iduals measured

the isothermal temperature coef ficient at three dif ferent control rod

j positions using data frem a cooldovn and heatup. The ITC was determined

correctly 5 out of 6 times indicating that the procedure was followed

and that the procedure was not in error. These personnel worked as a

team during the conduct of !he test and determined the rea:tivity change

and temperature change frem the x-y plot together rather than taking the

time to make totally independent calculations.

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NL.83.200.01

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Houston Lighting & Power Company

Attachment

ST-HL-AE-2741

Page 2 of 3

III Reason for Violatien (Cont.d) . ;

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The review process of Initial Startup Tests results includes reviews by

the Test Director, the Shif t Test Director, the Reactor Performance

Supervisor, the Reactor Support Manager, the Plant Engineering Manager, '

the Plant Operations Review Cc=mit. tee, and the Plant hanager. This

review chain is in addition to other independent second reviews that

take place during the performance of a test, as required by the test

procedure. The Test Director and the Shift Test Director review the

Test Packages primaril/ for technical adequacy, however, compliance

with progra==atic requirements is verified prior to submittal for

approval. After the Test Packages are raleased by the Shift Test ,

Director to the Reactor Performance Supervisor, subsequent reviews are

primarily for compliance with programmatic requirements and verificatica

that Acceptance Criteria are met. The Reactor Performance Supervisor 6

and the Reactor Support Manager do, however, review the Test Package for

technical adequacy, but not in the same detail as what is performed

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during test conduct and Test Package preparation. The Plant Operations ;

Review Committee and the Plant Manager review the ecmpleted Test Package

to verify that all acceptance criteria vere met. During the above

process none of the reviewers rechecked the x-y plot to ensure that the

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values used in the calculation were correct.

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IV Corrective Actions Taken and Results Achieved

A. Test Packages required for the Initial Criticality and Lov Power 1

Physics Test Plateaus have be'n reviewed for technical and

administrative compliance. As a result of this review, one

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additional calculational error was identified and corrected. The

test package in error was for procedure IVEPO4-ZX-0003, Boron

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Endpoint Determination. The error involved the Boren Endpoint for

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the all control rods inserted configurationi the corrected endpoint

i was 624.2 ppm instead of the 624.4 ppm previously recorded. Please l

note that there are no acceptance criteria for this particular

[ procedure. '

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B. In addition, a review of Cold and Hot Preeritical Test Packages was f

performed. Two additional calculational errors were discovered, ;

neither ci which affected the oatecce of the affected tests. These

! packages vill be corrected prior to the completio5 of the ?sitial *

Startup Test Program.

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f V. Corrective Actions Taken to Provsn't Recurrence

A. Procedure 1FE104-ZA-0003, Documentation of Initial Startup Test :

Results, has been revised to include a requirement to perform a >

random verification of calculptions made to support test results. l

1. This verification will be performed by an individual not directly ,

involved in the performance of the test.

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] 3. Test birectors and Shift Test Directors have been retrained on their i

responsibilities for Test Package reviews in particular on the t

I importance of performing independent reviews. i

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VI Full Compliance !

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Since the errors identified in Section IV.3. did not aff act the outccme

of any tests, the plant is in full compliance at this time. !

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Attachment

ST-HL-AE-2741

Page 1 of 2

South Texas Project Electric Generating Station

Unit'l

Docket No SIN 50-498

Response to Notice of Violation 8824-04

I Stateraent of Violation .

The TS Section 6.0 (Administrative Controls), Specification 6.8.1,

requires tnat procedures shall be established, implemented, and

. . maintained for plant operations.

Plant Procedure OPGP03-ZO-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 (sic)

requires that all valves inside the boundary shall be listed on the

clearance and shall be returned to tneir required operating position

prior to releasing boundary valves.

Contrary to the above, Plant Procedure CPGP03-ZO-0001, Revision 7, was

not followeu in that boundaries were not correctly controlled and the

associated valve within the boundaries were not properly listed en the

clearance as required in Step 5.1.3.b of the procedure. Specifically

drain valve LV-002L (sic) and LU-0119 vere 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 f rom the lube

oil sump onto the floor of the diesel generator building. *

II Houston Lighting & '.'ever Position

Houston Lighting & Power does not contest the violation.

Please note that in the statement of violation in your letter dated

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July 8, 1988 your ref erence to step 3.1.3.b should be 5.1.3.b and valve

LV-002L should be LU-0071.

III Reason for Violation

This violation occurred as the result of several factors which are

I listed below:

A. On shift operators did not comply with the requirements and

guidelines set forth in procedure CPGP03-ZO-0001, Equipment

Clearance, relating to establishing of system boundaries and the

l logging of components within those boundaries.

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ST-HL-AE-2742

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B. Information regardir.g the dra'ining of a major Diesel Generator

Support system was not relayed between shifts during shift

turnovers.

C. A full system line up verific,ation was not perfor=ed and operators

were not present during the starting of equipment af ter a major

system / equipment outage.

IV Corrective Actions Taken and Results Achieved

A. A directive has been issued to operations persennel reinforcing the

need to follow procedures and the policy of having an observer in

the vicinity when starting and stopping major equipment.

B. A memo has been issued to all operations perr nnel snowing the

sequence of events pertaining to soveral Station Problem Reports

involving the Equipment Clearance Procedure / Program.

C. Information regarding this incident has been circulated to all

operations personnel as required reading.

Y Corrective Actions Taken te Prevent Recurrence

The actions taken in Section IV should be adequata to provint

recurrence.

VI Full Compliance

The plant is in full compliance at this time.

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ML20154K368

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