ML20198F635
| ML20198F635 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/15/1998 |
| From: | Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| 50-498-98-09, 50-498-98-9, 50-499-98-09, 50-499-98-9, NUDOCS 9812280168 | |
| Download: ML20198F635 (5) | |
Text
_
.. -~
l l
9 UNITED STATES 4
E NUOLEAR REGULATORY COMMISSION o
O j
REGION IV g
611 RYAN PLAZA DRIVE, SUITE 400
William T. Cottle, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 l
SUBJECT:
NRC INSPECTION REPORT 50-498/98-09; 50-499/98-09
Dear Mr. Cottle:
Thank you for your letter of December 7,1998, in response to our November 12,1998, letter and Notice of Violation concerning maintenance instructions that were inappropriate to the circumstances in that the work instructions for the repair of the control circuit for the f 3 team Generator 2A startup feedwater regulating valve inappropriately specified steps that affected the operation of the Steam Generator 2A normal feedwater regulating valve. We have reviewed your reply and fi,nd it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
We have also reviewed your additional comments in the cover letter of your response where you stated that the inappropriate work instruction change was the result of the root cause of the
. event and not the significant contributing cause. We agree that the change made in the work instruction was not the root cause, but we do believe it was a significant contributor to the j
event.
If you wish to discuss this further, please contact me at (817) 860-8243.
Sincer r
Jo ph I. Tapia Chief oject Branch A Division of Reactor Projects Docket Nos.: 50-498 50-499 License Nos.: NPF-76 l
NPF-80 9812280168 981215 PDR ADOCK 05000498 G
. -....- =
- STP Nuclear Operating Company,
cc:
l Lawrence E. Martin, Vice President i
Nuclear Assurance & Licensing STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 p
A.~ Ramirez/C. M. Canady l
City of Austin Electric Utility Department 721 Barton Springs Road i
Mr. M. T. Hardt/Mr. W. C. Gunst City Public Service Board P.O. Box 1771 San Antonio, Texas 78296 l
D. G. Tees /R. L. Balcom Houston Lighting & Power Company
- P.O. Box 1700 i
L
. Houston, Texas 77251 Jon C. Wood Matthews & Branscomb One Alamo Center 106 S. St. Mary's Street, Suite 700 San Antonio, Texas 78205-3692 Jack R. Newman, Esq.
1800 M. Street, N.W.
Washington, D.C. 20036-5869 Mr. G. E. Vaughn/Mr. C. A. Johnson Central Power & Light Company P.O. Box 289 MailCode: N5012 Wadsworth, Texas 77483 INPO Records Center l'
700 Galleria Parkway Atlanta, Georgia 30339-5957 f
l
+
STP Nuclear Operating Company Bureau of Radiation Control
~
State of Texas 1100 West 49th Street Austin, Texas 78756 Mr. Jim Calloway.
. Texas Public Utility Commission William B. Travi-s Building.
1701 North Congress Avenue P.O. Box 13326 Austin, Texas 78701-3326 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 i
1-
STP Nuclear Operating Company
-4 DEC 151998 fM6WQ'K/
bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS-PSB Bre.nch Cnief (DRP/A)
MIS System Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
R. Bachmann, OGC (MS: 15-B-18) l l
1
\\
230080 T
DOCUMENT NAME: R:\\_STP\\ST809AK.DPL TLreceive copy of document. Indic.ete in box: "C" = Copy without enclosu es *E' = Copy with enclosures "N" - No copy C:DRP/AA l
RIV:PE:DRP/Aa RAKopriva;df WV JITapia MQA$ >
l
~
12// 6/98 12/ N/08 li i
@FICIAL RECORD COPY f.;
Y
STP Nuclear Operating Company DEC i 51998 bec to DCD (IE01) bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS-PSG Branch Chief (DRP/A)
MIS Systera Project Engineer (DRP/A)
RIV File Branch Chief (DRP/TSS)
R. Bachmann, OGC (MS: 15 B-18) i DOCUMENT NAME: R:\\_STP\\ST809AK.DPL To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy 1
RIV:PE:DRP/Ain C:DRP/AA RAKopriva:df WV JITapia 44%)>
12// 6/98 12/ K/98 ll (
&FICIAL RECORD COPY l
)
l
Nen n n-
.r se m.mpwseecm myJmmn naarm met am mu m
l l
December 7,1998 l
NOC-AE-000371 File No.: G02.04.02 10CFR2.201 STI: 30779114 U. S. Nuclear Regulatory Commission
. Attention: Document ControlDesk k
@ @ @ g g y 7l l
Washington, DC 20555 l
DEC l l1998 i
South Texas Project i
Units 1 and 2 REGIONIV l
Docket Nos. STN 50-498; STN 50-499
~
Reply to Notice of Violation 9809-03 South Texas Project has reviewed the Notice of Violation contained in inspection report 50-498; 499/98-09 dated November 12,1998, and submits the attached reply. The only commitments l
contained in this correspondence are located in the Corrective Actions section of the attachment, i
The cover letter of NRC Inspection Report 50-498/98-09; 50-499/98-09 stated "The change to the work instructions was inappropriately made as a minor change and received no review. 'Your review of this event did not ; %ify thiMgnificant contributing cause". STP Nuclear Operating Company was asked to " incbde your actions to address the inappropriate method used to change l
the affected work instructions."
l STP Nuclear Operating Company agrees that the procedure for making a " pen and ink" change was not followed properly in this case and that the work instructions were changed inappropriately. The Corrective Action Program Report for this event has identified a procedural compliance concern and has established actions to address this concern. Nevertheless, STP Nuclear Operating Company focus continues to be on " why" the work instructions were changed inappropriately. Our root cause analysis process has identified a cause that answers this question and provides corrective actions (see Unit 2 Licensee Event Report 98-002). As stated in Unit 2 Licensee L
Event Report 98-002, corrective action 4 is designed to widely disseminate the lessons learned from L
this event. The case study being developed will communicate the reasons for the required procedural l
1 steps and the possible results when work instructions are inappropriately changed. In addition to j'
sharing this information with all pertinent individuals, STP Nuclear Operating Company intends to assess the pen and ink change process and ensure the correct checks and balances are in place. This action has been captured as an enhancement activity within our corrective action process since it is not directly related to addressing the root cause. In addition, this specific inappropriate action was considered during the development ofindividual, personal corrective actions. In sununary, STP
.o: W W 9:ws09
)). y]g L
ffr/.9/fDM f
. -.f/' -
NOC-AE-000371 File No.: G02.04.02 Page 2 Nuclear Operating Company does not believe we failed to identify a significant contributing cause, but sees the inappropriate work instruction change as a result of the root cause of the event.
If there are any questions regarding this reply, please contact Mr. W. E. Mookhock at (512) 972-7274 or me at (512) 972-7988.
j olh Robert E. Masse Plant Manager, Unit 2 WEM Attachments: Reply to Notice of Violation 9809-03 i
e'
.N!
l l
g4
~ 0:wpWWoepimov-989809
l' L
NOC-AE-000371 l
Pile No.: 002.04.02 Page 3 l
. c:
l Ellis W. Merschoff Jon C. Wood Regional Administrator, Region IV Matthews & Branscomb U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington, TX 76011-8064 San Ar.tonio, TX 78205-3692 ThomasW. Alexion Institute of Nuclear Power Project Manager, MailCode 13H3 Operations - Records Center
' U.' S. Nuclear Regulatory Commission
- 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 Cornelius F. O'Keefe Richard A. Ratliff
. Sr. Resident Inspector Bureau of Radiation Control c/o U. S. Nuclear Regulatory Conunisslon Texas Department of Health P. O. Box 910 1100 West 49th Street Bay City, TX 77404-0910 Austin, TX 78756-3189 J. R. Newman, Esquire
' D. G. Tees /R. L. Balcom Morgan, lewis & Bockius Houston Lighting & Power Co.
1800 M. Street, N.W.
P. O. Box 1700 s
Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service ATrN: O. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012
[
San Antonio,TX 78296 Wadswonh,TX 77483 A. Ramirez/C. M. Canady U. S. Nuclear Regulatory Commission -
f City of Austin Attention: Document Control Desk
' Electric Utility Department Washington, D.C. 20555-0001
~ 721 Barton Springs Road Austin,TX 78704 l-j-
k
-r 4
,%-r
--ew, a
Attachment l,
NOC-AE-000371 l.
Page 1 of 2 i
Reply to Notice of Violation 9809-03 1.
Statement of Vicktion; During a NRC inspection conducted on September 6 through October 17,1998, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below; i
Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented and maintained covering the appilcable procedures remmmerwhi in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A reenmman% in part, that maintenance that can affect the performance of safety-rclated equipment be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, on Septunber 22, Work Order BS-354091 contained maintenance Instructions that were inappropriate to the circumstances. Specifically, tie work order intended to repair the control circuit for the Steam Generator (SG) 2A startup feedwater regulating valve, i
inappropriately specified steps that affected the operation of the SG 2A normal feedwater regulating valve. When the steps were performed, feedwater flow was lost to SG 2A, resulting in a plant trip while Unit 2 was operating at 100 percer* reactor power.
This is a Severity Level IV violation (Supplement 1) (499/98009-03).
II.
South Texas Project Position:
I South Texas Project concurs that the violation occurred.
)
III.
Reasbn for the Violation:
As stated in Licensee Event Report 98-002 for South Texas Project Unit 2, 'The cause of l
this event was the failure to adequately verify the technical accuracy of changes made to the original work instructions".
IV.
Conective Actions:
Licensee Event Report 98-002 for South Texas Project unit 2 identified the following sa corrective actions:
1 U:\\wpn rareapnov-989809 e
^ ' ' ~
Attachment l
NOC-AE-000371 Page 2 0f 2
- 1. I.cssons learned were discussed and personnelissues were addressed with the personnel involved in the event. (Completed September 29,1998)
- 2. Lessons learned from the event were discussed with plant operations personnel, as well as l
craft personnel of all maintenance disciplines. (Completed September 23,1998)
- 3. AllInstrumentation & Control work packages worked over the next few days were l
thoroughly reviewed for similar problems prior to performance. (Completed September l
23, 1998) l
- 4. A case study or studies to include principles, roles and responsibilities will be developed t
and presented to key stakeholders. (Due January 28,1999)
V.
Date of Full Compliance:
l South Texas Project is in full compliance.
l l
l I
l l
t 3
i OAwpinhrc.ap%v-989409 i
,