ML20245A161
| ML20245A161 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/15/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8906210124 | |
| Download: ML20245A161 (2) | |
See also: IR 05000498/1989007
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In' Reply Refer To:
Dockets: 50-498/89-07
50-499/89-07
Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P.O. Box 1700
Houston, Texas77001
Gentlemen:
Thank you for your letter of May 31, 1989, in response to our letter' and
Notice of Violation dated May 1,1989. We have reviewed your reply and find 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
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determine that full compliance has been achieved and will be maintained,
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Sincerely,
Original Signed By-
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James L. Milhoan, Director
Division of Reactor. Projects
cc:
Houston Lighting & Power Company
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ATTN:
M. A. McBurnett, Manager
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Operations Support Licensing
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P.O. Box 289
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Wadsworth, Texas 77483
Houston Lighting & Power Company
ATTN: Gerald E. Vaughn, Vice President
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Nuclear Operations
P.O. Box 289
Wadsworth, Texas 77483-
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Ho,uston Lighting & Power CompanyJ
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ATTN:
J. T. Westermeier, General Manager!
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South Texas Project
P.O. Box 289
Wadsworth, Texas 77483
Central Power & Light Company
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ATTN:
-R. L. Range /R. P. Verret
P.O. Box 2121
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Corpus Christi, Texas 78403
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City of Austin Electric Utility
ATTN:
R. J. Miner, Chief Operating.
Officer
721 Barton Springs Road
Newman & Holtzinger, P.C.
ATTN:
J. R. Newman, Esquire
,
1615 L Street, N.W.
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Washington, D.C. '20036
Houston Lighting & Power Company
ATTN:
S. L. Rosen
P.O. Box 289
Wadsworth, Texas 77483
Houston Lighting & Power Company
ATTN:
R. W. Chewning, Chairman
Nuclear Safety Review Board
P.O. Box 289
Wadsworth, Texas 77483
City Public Service Board
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ATTN:
R. J. Costello/M. T. Hardt
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P.O. Box 1771
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San Antonio, Texas- 78296
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Houston Lighting & Power Cnmpany
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ATTN: Licensing Representative
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Suite 610
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Three Metro Center
Bethesda, Maryland 20814
Texas Radiation Control Program Director
bectoDMB(IE01)
bec distrib. by RIV:
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Section Chief (DRP/D)
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Lisa Shea, RM/ALF
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G. Dick,NRRProjectManager(MS:
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R. D. Martin
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Project Engineer (DRP/D)
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liouston Lighting & Power
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May 31, 1989
ST-HL-AE-3116
File No.: G02.04
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10CFR2.201-
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U. S. Nuclear Regulatory Commission
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Attention: Document Control Desk
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20555
South Texas Project Electric Generating Stativn
Unit 2
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Docket No. STN 50-499
Response to Notice of Violation 499/8907-01
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Houston Lighting & Power Company has reviewed the four parts of Notice
of Violation 499/8907-01 dated May 1, 1989, and submits the attached responses
pursuant to 10CFR2.201.
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.b kn
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G. E. Vaughn bb
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Vice President
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Nuclear Operations
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GEV/PLU/eg
Attachments:
1) Response to Notice of Violation 499/8907-01, Part 1
2) Response to Notice of Violation 499/8907-01, Part 2
3) Response to Notice of Violation 499/8907-01, Part 3
4) Response to Notice of Violation 499/8907-01, Part 4
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A1/042.NL1
A Subsidiary of Houston Industries Incorporated
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Anuston Lighting & Power Company
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ST-HL-AE-3116
File No.:
G02.04
Page 2
Cet
Regional Administrator, Region IV
Rufus S. Scott
Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 1000
Houston Lighting & Power Company
Arlington, TX 76011
P. O. Box 1700
Houston, TX 77001
George Dick, Project Manager
U. S. Nuclear Regulatory Commission
Washington, DC 20555-
Records Center
1100 Circle 75 Parkway
Jack E. Bess
Atlanta, Ga. 30339-3064
Senior Resident Inspector-Unit I
c/o U. S. Nuclear Regulatory Commission
Dr. Joseph M. Hendrie
P. O. Box 910
50 Be11 port Lane
Bay City, TX 77414
Be11 port, NY 11713
J. I. Tapia
Senior Resident Inspector-Unit 2
c/o U. S. Nuclear Regulatory Commission
P. O. Box 910
Bay City, TX 77414
J. R. Newman, Esquire
Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036
R. L. Range /R. P. Verret
Central Power & Light Company
P. O. Box 2121
Corpus Christi, TX 78403
R. John Miner (2 copies)
Chief Operating Officer
City of Austin Electric Utility
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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Revised 12/21/88
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Attachment 1
ST-HL-AE-3116-
Page 1 of 2
South Texas Project Electric Generating Station
Unit 2
Docket No. STN 50-499
Response to Notice of Violation 499/8907-01. Part 1
I.
Statement of Violation. Part 1
Station Procedure OPGP03-ZF-0004, Revision 1, " Control of
Transient Fire Loads," Section 4.14, states that plant areas shall
not be used for bulk storage of combustible material except as
evaluated by the fire protection coordinator and approved by
management.
Such storage shall be posted (including required
precautions and storage conditions) using a Combustible Material
Storage Authorization Form.
Contrary to the above, on March 15, 1989, combustible materials
(mop handles, mop heads, plastic bags, and cleaning rags) were
found stored outside of their storage locker in Room.301
(electrical penetration area), while the approved Combustible
Material Storage Authorization w88-071 attached to the locker
stated that this material was to be stored inside the locker with
the doors closed.
II.
Houston Lighting & Power Position
HL&P concurs that the cited violation occurred.
III.
Reason for Violation
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The root cause of this violation is lack of attentiveness to
housekeeping requirements by members of the janitorial staff.
IV.
Gprrective Action Taken and Results Achieved
The following corrective actions have been taken in response to
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this violation:
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1.
The subject material was properly stored.
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2.
All individuals involved received a verbal reprimand.
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Attachment 1
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ST-HL-AE 3116
Page 2 of 2
South Texas Project Electric Generating Station
Unit 2
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Docket No. STN 50-499
Response to Notice of' Violation 499/8907-01. Part 1
V.
Corrective Actions Taken to Prevent Recurrence
Immediate corrective actions included giving verbal reprimands to
the individuals involved and directing Ebasco supervision over-
laborers assigned to janitorial duties in STPEGS Units 1 and 2 to
comply with fire safety requirements.
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In addition, Ebasco personnel involved in janitorial activities in
STPEGS Units 1 and 2 are being formally notifled that:
1.
Violation of fire safety requirements may result in-oral
or written warnings.
2.
Repeated violations of fire safety requirements or a
severe violation of those requirements may be grounds-for
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termination of employment at STPEGS.
3.
Repeated violation of fire safety requirements concerning
storage of combustible materials (i.e., janitorial tools
and supplies) may result in revocation of permission.to
store those materials inside the power block.
Completion is expected by June 27, 1989.
VI.
Date of Full Compliance
HL&P is in full compliance at this time.
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Attachment 2
ST-HL-AE-3116
Page 1 of 2
South Texas Project Electric Generating Stttion
Unit 2
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Docket No. STN 50-499
Response to Notice of Violation 499/8907-01. Part 2
1.
Statement of Violation. Part 2
Station Procedure OPGP03-ZI-0002, Revision 2, " Erection and Use of
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Temporary Scaffolding," Section 4.1.1, states that project
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engineering shall inspect scaffolding built over and around
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Category 1 safety-related components.
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Contrary to the above, temporary scaffoldin5 was erected in the
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overhead of all three of the emergency cooling water (ECW) pump
bays without an inspection and evaluation by project engineering,
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The scaffolding was directly above safety-related cable trays.
II.
Houston Lichtita_ & Power Position
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HL&P concurs that the cited violation occurred.
III.
Reason for Violation
The root cause of the violation was an inadequate procedure which
resulted in failure to sufficiently control use of scaffolding.
IV.
Corrective Action Taken and Results Achieved
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The subject temporary scaffolding has been removed.
In addition,
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all accessible areas of both Units have received a co'aplete
walkdown, and all open scaffolding work documents have been
reviewed to determine completeness and compliance with
OPGP03-ZI-0002.
Inaccessible areas, i.e. Unit 1 and Unit 2
Reactor Containment Buildings, have each been verified as being
scaffold-free as part of the final verification prior to initial
criticality for Unit 2 and during final verification of BMI 3 work
activities for Unit 1.
Deficiencies discovered during the
investigation have been corrected.
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Attachment 2
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ST-HL-AE-3116
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Page 2.of 2'
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South Texas Project Electric Generating Station
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Unit 2
Docket No. STN 50-499
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Resoonse to Notice of Violation 499/8907-01. Part 2
V.
Corrective Actions Taken to Prevent Recurrence
In order to prevent recurrence, the following actions have been
initiated:
1.
A computer data base has been implemented allowing for
detailed management.of the scaffolding in Units 1 and 2.
2.
Programs at other sites have been reviewed to develop
recommendations for improving the STPEGS program.
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3.
Procedure OPGP03 ZI-0002 is to be revised to' provide more
detailed control of the scaffold program and to
incorporate recommendations provided under (2).
The
revision is expected to be completed by July 31, 1989.
VI.
Date of Full Como11ance
HL&P is in full compliance at this time.
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ST-HL- AE-3116
Page 1 of 2
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South Texas Project Electric Generating Station
Unit 2
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Docket No. STN 50-499
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Response to Notice of Violation 499/8907-01. Part 3
1.
Statement of Violation. Part 3
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Station Procedure OPGP03-ZA-0002, Revision 16, " Plant Procedures,"
Section 14.2.1, states that the procedure reviewer of a converted
procedure shall verify that' Field Change Requests-(FCRs) were
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incorporated correctly.
Contrary to the above, two examples were found where the procedure
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reviewer did not verify that FCRs were correctly incorporated into
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a converted procedure. These examples were:
A field change request initiated per instructions in
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Unreviewed Safety Question Evaluation (USQE) 88-0146 to
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instruct the operator concerning control of the ECW
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chiller condenser pressure was not incorporated into the
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procedure,
Valve 2-SI-0121A (Low Head Safety Injection Pump 2A flush
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line isolation valve) was omitted from Procedure
Checklist 2 POP 02-SI-0002-1 because an FCR was not
incorporated into the procedure.
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II.
Houston Lichting & Power Position
HL&P concurs that the FCRs were not correctly
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incorporated in the procedures; however, in the
examples given, the procedures were revised in
accordance with section 5.0 of OPGP03-ZA 0002, rather
than converted in accordance with Section 14.2.1.
III. Reason for Violation
The root cause of this violation is an inadequate procedure
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approval process in which an FCR could be issued against a
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procedure and not be evaluated for incorporation into the next
revision prior to the issuance of the new revision.
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IV.
Corrective Action Taken and Results Achieved
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Current quality-related procedures'have been reviewed to determine
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the extent of this concern. Additional discrepancies were found
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in which FCRs were not incorporated in current procedure
revisions. The affected procedures have been corrected as
appropriate.
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Attachment 3
ST-HL AE-3116
Page 2 of 2
South Texas Project Electric Generating Station
Unit 2
Docket No STN 50-499
Response to Notice of Violation 490/8907-01. Part 3
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V.
Corrective Actions Taken to Prevent Recurrence
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As a long-term corrective measure, OPGP03 ZA-0002 will be revised
to ensure that FCRs are incorporated into the next revision of the
procedure prior to its issuance.
This revision is expected to be
completed by June 30, 1989.
In the interim, the following additional controls have been
implemented:
1.
For revisions to plant procedures, a list of FCR's
(excluding one-time-only) issued against the old revision
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of the procedure that were evaluated'during the revision
process shall be included on Form OPGP03-ZA-0002-2.
2.
Prior to issuing a new procedure revision, Procedure
Control personnel shall ensure.the FCR's listed in (1)
match the Procedure Control listing of outstanding FCR's
against the previous revision.
If there is a
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discrepancy, Procedure Control shall not issue the new
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revision until it is revised to include the additional
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FCR's.
VI.
M e of Full Compliance
HL&P is in full compliance at this time.
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Attachment 4
ST-HL-AE-3116
Page 1 of 2
South Texas Project Electric Generating Station
Unit 2.
Docket No. STN 50-499
Resoonse to Notice of Violation 499/8907-01. Part 4
I.
Statement of Violation. Part 4
The licensee documented an Unreviewed Safety Question Evaluation
(USQE) #88-0146 for a temporary modification to the emergency
cooling water (ECW) system. 'This USQE required an appropriate
emergency operating procedure revision to direct manual operator
action for essential chiller operation when the ECW pond
temperature exceeds 53'F following an event.*
- Note:
The subject of USQE 88-0146 was operation of the
essential chillers at ECW pond temperature less than
54'F.
Contrary to the above, activities affecting quality were not
prescribed by procedures appropriate to the circumstances in that
the emergency operating procedure revision was not made to direct
manual operation as required by USQE 88-0146.
II.
Houston Lighting & Power Position
HL&P concurs that a violation occurred.
III. Reason for Violation
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The root cause of this violation was a breakuown in the review and
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approval process for unreviewed safety question evaluations. USQE
88-0146 included, as an attachment, a list prepared by design
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engineering personnel of procedural changes considered appropriate
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to ensure that manual operator actions for essential chiller
operation at reduced ECW pond temperature would be carried out.
This list was not correct.
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This USQE was discussed with the Plant Operations Review Committee
(PORC) via a telephone conference on a weekend evening.
members did not have copies of the USQE and attachments for
reference during this conference. The more significant parts of
the USQE were read verbatim to the PORC, including the responses
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to the three major criteria for determining whether the change
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constituted an unreviewed e.afety question.
Changes to plant
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operating procedures were generally discussed. PORC amended the
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USQE to direct that the essential chillers be declared inoperable-
below ECW pond temperature of 45'F.
(This determination was based
on test data. Chiller operation at ECW pond temperatures in the
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range of 45'F to 54'F was found to not constitute an unreviewed
safety question.)
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Attachment 4
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ST-HL- AE-3116
Page 2 of 2
South Texas Project Electric Generating Station
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Unit 2
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Docket No. STN 50-499
Response to Notice of Violation 499/8907-01. Part 4
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However, not all of the USQE attachments were read verbatim to the
PORC. Specifica'ly, the list of procedure changes was not
discussed in detail and, as a result, the PORC members failed to
detect the errors on the list.
The operations personnel making the procedure changes discovered
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the errors on the list and made changes to the appropriate
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procedures. Necessary and appropriate procedure changes were
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implemented prior to operation of the essential chillers at
reduced ECW pond temperature.
No changes to emergency operating
procedures were required.
IV.
Corrective Action Taken and Results Achieved
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All necessary and appropriate procedure changes were implemented
prior to operation of the essential chillers at reduced ECW pond
temperature. No changes to emergency operating procedures were
required.
V.
Corrective Actions Taken to Prevent Recurrence
Since this event, the PORC has not conducted a review and made a
recommendation to the Plant Manager on the basis of a telephone
conference.
The PORC will not in the future make a recommendation
to the Plant Manager on the basis of a telephone conference
without each individual PORC member being in possession of the
pertinent information.
To ensure future compliance, a " Note" to
this effect has been added by field change to procedure
OPGP03-ZA-0004, " Plant Operations Review Committee."
VI.
Date of Full Comoliance
HL&P is in full compliance at this time,
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