ML20207M822
| ML20207M822 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/10/1999 |
| From: | Sheppard J HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-498-98-15, 50-499-98-15, MPC-AE-000458, MPC-AE-458, NUDOCS 9903190204 | |
| Download: ML20207M822 (6) | |
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Nuclear Operating ompany S
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NOC-AE-000458 l
File No.: G02.04.02 10CFR2.201 1
STI: 30825375 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,DC 20555 i
i South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Response to Notice of Violation 98015-02 South Texas Project has reviewed the Notice of Violation contained in Inspection Report 50-498/499 98015 dated February 10,1999, and submits the attached reply. The only commitments contained in this correspondence are located in the Corrective Actions section of the attachment.
South Texas Project continues to believe that our performance during this event did not meet our i
expectations. The operability decision made regarding the ElB11 battery did not consider all necessary information, nor was there a complete understanding of battery operation. However, South Texas Project believes that the requirements of Technical Specification 3.8.2.1 were met I
during the event and therefore, we must respectfully deny that a violation occurred. Our position is explained in Attaclunent 1 of this letter. Notwithstanding our position with respect to the violation, South Texas Project understands our shortcomings during this event, and has included corrective actions in Attachment I for your information.
I If there are any questions regarding this information, please contact Mr. W. E. Mookhoek.~
(512) 972-7274 or me at (512) 972-8757.
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J. J. Sheppard Vice President and Special Assistant to the President i
180031-90 1 b
WEM Attachments: 1. Response to Notice of Violation 98015-02 j
9903190204 990310 7
PDR ADOCK 05000498 e
PDR a i
k:\\wphtarc-spbov.99\\98015 j
c NOC-AE-000458 File No.:G02.04.02 G03.17 Page 2 cc:
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 St.eet, Suite 700 Arlington, TX 76011-8064 San Antonio,TX 78205-3692 Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 Comelius F. O'Keefe Richard A. Ratliff St. Resident Inspector Bureau of Radiation Control c/o U. S. Nuclear Regulatory Commission 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 l
Washington, DC 20036-.5869 Houston,TX 77251 l
M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service ATTN: G. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 78296 Wadsworth,TX 77483 A. Ramirez/C. M. Canady U. S. Nuclear Regulatory Commission City of Austin Attentwn: Document Control Desk Flectric Utility Department Washington, D.C. 20555-0001 721 Bartoa Springs Road Austin,TX 78704 l
NOC-AE-000458 Page 1 of 4 Reply to Notice of Violation 98015-02 I.
Statement of Violation:
During a NRC inspection conducted on June 14 through November 23,1998, 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:
Technical Specification 3.8.2.1 is applicable while the reactor is in Mode 1 and states, "As a minimum, the following D.C. electrical sources shall be OPERABLE... Channel III 125-volt Battery Bank ElB11." The associated action statement requires, "With one of the required battery banks inoperable, restore the inoperable battery bank to OPERABLE ctatus within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
Contrary to the above, from June 14 at 8:02 p.m. until June 15,1998, at approximately 10:37 a.m., a period yeater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, Unit 1 Channel III 125-volt Battery Bank ElBil was inoperable with the reactor in Mode 1 and the reactor was not placed in at least hot standby within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This is a Severity Level IV violation (Supplement I).
II.
South Texas Proiect Position:
South Texas Project does not agree that a violation of Technical Specifications occurred. South Texas Project believes we were in compliance with Technical Specification 3.8.2.1 requirements during the specified period, even though a proper operability evaluation was not performed at the time.
At 1705 on June 14,1998 the Unit I control room was notified of smoke in the ESF 4.16kv Train B Switchgear. The Switchgear was deenergized at 1708. The cause of the fire was later determined to be a failure of a potential transformer in the switchgear. The staff was focused on the rertoration of power to the ElB bus during this event and thus the restoration of a battery charger. The staff erroneously believed that the battery would remain OPERABLE as long as the terminal voltage remained above 110 volts. As stated in the inspection report, there was a demonstrated lack of battery operation knowledge during this event. The staff believed that the battery remained OPERABLE during the entire duration of the event and did not question the status of the battery until the question of operability was raised by the NRC Resident Inspector.
Once prompted, the staff took action to investigate the question of battery operability even though we still believed the battery was operable. South Texas Project believes that the consideration given to battery opembility was incorrect and incomplete; however, the subsequent i
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NOC-AE-000458 Page 2 of 4 analysis did determine the battery to be operable before the plant was brought into Mode 3. This l
process did not meet station expectations and actions have been taken to correct the deficiencies discovered during this event.
I Even though the c'ecision making process for exiting all Limiting Conditions for Operation invoked as a result of this event was flawed, South Texas Project believes that a violation of Technical Specifications did not occur. The timeline that occurred during the event had the station battery recharged to a point where it satisfied the Technical Specification requirements for specific gravity, and thus battery capability, before the plant was required to be in Mode 3. This occurred fortuitously and not by any specific actions taken by the staff. Analysis of the battery condition, performed after the event, and acknowledged by the inspection report, demonstrated that the battery could have performed its intended function throughout the event. The analysis calculated the actual design bases capability of the battery and proved that the battery was capable of performing its two-hour post-accident duty cycle.
The position taken in Inspection Report 98015 stated that when the individual cell voltage dropped below 2.07 volts, the battery became inoperable. The battery would not be able to satisfy this requiremem without a charger even though it was fully capable of performing its intended safety function. South Texas Project believes that this parameter does not relate to operability, but defines a point of condition for the battery where comparisons may be made from test to test, similar to those used by Section XI testing for mechanical systems. Therefore, we believe that the position taken in the Inspection Report is not germane to OPERABILITY in this case. The battery vendor evaluated battery capability during this event. The result of this evaluation supports the conclusion reached by the South Texas Project.
Conclusion Although South Texas Project believes we were in compliance with Technical Specification 3.8.2.1 requirements during the specified period, we recognize that our performance was lacking during this event and have completed corrective actions to address these issues.
l III.
Reason for the Violation:
As noted above, South Texas Project does not believe that a violation occun ed.
IV.
Corrective Actions:
1 The following corrective actions have been taken with respect to this issue:
- 1. Additional training on battery fundamentals was developed and delivered to all appropriate personnel that included:
the effect of partial discharge on specific gravity and battery operability e
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4 NOC-AE-000458 Page 3 of 4 how to interpret battery capacity based on discharge and charge current levels the accuracy of specific gravity testing during charge and discharge cycles e
application of Technical Specification 3.8.2.1.
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- 2. The supervisory oversight lessons learned from this event were incorporated into the Conduct of Operations Manual.
- 3. Procedure OPOP02-EE-0001, ESF (Class 1E) DC Distribution System was revised to include information for battery operability determinations during and following discharge events.
- 4. Procedure OPOP04-DJ-0001, Loss of Class 1E 125 VDC Power was revised to include a " NOTE" delineating the limits imposed in procedure OPOP02-EE-0001.
- 5. Procedure OPOP04-AE-0001, Loss of Any 13.8 kV or 4.16 kV Bus was revised to include a " CAUTION" delineating the limits imposed in procedure OPOP02-EE-0001 during partial battery discharges. The revision to OPOP04-AE-0001 also included Technical Specification lessons learned from this event.
- 6. Procedure OPSP06-DJ-0001,125 Volt Class 1E Battery 7 Day Surveillance Test, and i
0 PSP 06-DJ-0002125 Volt Class 1E Battery Quarterly Surveillance Test was revised to include clarification on the accuracy of specific gravity measurements during charge and discharge cycles and Coat conditions.
l V.
Date of Full Compliance:
l South Texas Project continues to be in full compliance.
VI.
Additional Information:
The cover letter ofInspection Report 50-498; 50-499/98015 requested South Texas Project to provide a description of our corrective actions to ensure that knowledge and plant procedures are adequate to promptly restore power to safuy-related equipment following a station blackout.
The corrective actions listed above address this issue as well as others identified by our review of this event. In addition to those actions listed in this attachment as corrective actions, a number of other enhancements are included below that will improve our processes:
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- 1. All engineering personnel that perform or direct surveillance procedure performance I
have been trained on the importance of surveillance procedure performance for operability testing. This training stressed the difference between the use of a surveillance procedure for support of a work order and for operability tecing.
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NOC-AE-000458 Page 4 of 4 I
- 2. South Texas Project has developed and will implement a modification for the safety related 480-volt load center feeder breaker handswitches on the Main Control Board to l
prevent tripping the breakers in similar circumstances due to activation of the " anti-pump relay". These modifications will be installed in the plant during the refueling outages scheduled for sprit.g and fall this year.
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