ML20154K368
| 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) | |
See also: IR 05000498/1988024
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In Reply Refer To:
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Dockets: 50-498/88-24
and
50-498/88-11
50-499/88-11
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Houston Lighting & oower Company
ATTN:
J. H. Goldberg, Group Vice
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President. Nuclear
P.O. Box 1700
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Houston, Texas 77001
Gentlemen:
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Thank you for your letter dated August 3,1988, in response to our
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letter dated July 8,1988. We have no further questions at this time and will
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review your corrective action during a future inspection.
Sincerely,
Onkinal Styned Bp
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A.B. BEACH
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L. J. Callan Director
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Division of Reactor Projects
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Houston Lighting & Power Company
Newman & Holtzinger, P.C.
ATTN:
M. A. McBurnett, Manager
ATTN:
J. R. Newman, Esquire
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Operations Support Licensing
1615 L Street, N.W.
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P.O. Box 289
Washiagton, D.C.
20036
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Wadtworth, Texas 77483
Houston Lighting & Power Company
Houston Lighting & Power Company
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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
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South Texas Project
Nuclear Safety Review Board
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P.O. Box 289
P.O. Box 289
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Wadsworth, Texas 77483
Wadsworth, Texas 77483
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8009230298 880919
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ADOCK 05000498
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Houston Lighting & Power Company
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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
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Corpus Christi, Texas 78403
San Antonio, Texas 78296
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City of Austin Electric Utility
Houston Lighting & Power Company
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ATTN:
R. J. Miner, Chief Operating
ATTN: Licensing Representative
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Officer
Suite 610
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721 Barton Springs Roed
Three Metro Center
Bethesda, Maryland 20814
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Texas Radiation Control Program Director
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bec to DNS (IE01)
bec distrib. by RIV:
RRI-OPS
R. D. Martin, RA
SectionChief(DRP/D)
RPB-DRSS
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MIS System
RIV File
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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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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
Our response to violation 8824-01 vill be submitted by separato
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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
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ST-HL-AE-2741
File No.: G2.04
Pags 2
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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
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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
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Don L. Garrison
Resident Inspector / Construction
c/o U. S. Nuclear Regulatory Commission
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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
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721 Barton Springs Road
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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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Attachment
ST-HL-AE-2741
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Page i of 2
South 72xas Project Electric Generating Statien
Unit 1
Docket No STN 50-498
Response to Notice of Violation 8811-02
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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
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hours or the plant must be shut down in accordance with the action
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 <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 />.
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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.
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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
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July 8, 1988 tha reference to T.S. 3.52 should be 3.5.2.
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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
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Houstdn Lighting & Power Company
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Attachment
ST-HL-AE-2741
Page 2 of 2
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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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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.
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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
ST-HL-AE-2741
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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
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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.
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Houston Liehtine & Power Position
Houston Lighting & Power does not contest the violatius.
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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
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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
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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,
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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
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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
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and the Reactor Support Manager do, however, review the Test Package for
technical adequacy, but not in the same detail as what is performed
during test conduct and Test Package preparation.
The Plant Operations
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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
values used in the calculation were correct.
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Corrective Actions Taken and Results Achieved
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Test Packages required for the Initial Criticality and Lov Power
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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
Endpoint Determination. The error involved the Boren Endpoint for
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the all control rods inserted configurationi the corrected endpoint
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was 624.2 ppm instead of the 624.4 ppm previously recorded.
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note that there are no acceptance criteria for this particular
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procedure.
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In addition, a review of Cold and Hot Preeritical Test Packages was
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performed. Two additional calculational errors were discovered,
neither ci which affected the oatecce of the affected tests. These
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packages vill be corrected prior to the completio5 of the ?sitial
Startup Test Program.
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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
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random verification of calculptions made to support test results.
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This verification will be performed by an individual not directly
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involved in the performance of the test.
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Test birectors and Shift Test Directors have been retrained on their
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responsibilities for Test Package reviews in particular on the
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importance of performing independent reviews.
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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
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Stateraent of Violation
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The TS Section 6.0 (Administrative Controls), Specification 6.8.1,
requires tnat procedures shall be established, implemented, and
maintained for plant operations.
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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.
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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.
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Reason for Violation
This violation occurred as the result of several factors which are
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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
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logging of components within those boundaries.
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ST-HL-AE-2742
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Information regardir.g the dra'ining of a major Diesel Generator
B.
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.
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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.
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Corrective Actions Taken te Prevent Recurrence
The actions taken in Section IV should be adequata to provint
recurrence.
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Full Compliance
The plant is in full compliance at this time.
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