View source for ST-HL-AE-2608, Responds to Violations Noted in Insp Rept 50-498/88-09. Corrective Actions:Evaluation of Maint Work Request Generation & Approval Process Performed,Cases Where Testing Frequency Changed Verified & 1TSP03-CV-0001 Generated

{{Adams
| number = ML20151E749
| issue date = 04/08/1988
| title = Responds to Violations Noted in Insp Rept 50-498/88-09. Corrective Actions:Evaluation of Maint Work Request Generation & Approval Process Performed,Cases Where Testing Frequency Changed Verified & 1TSP03-CV-0001 Generated
| author name = Vaughn G
| author affiliation = HOUSTON LIGHTING &amp; POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000498
| license number = 
| contact person = 
| document report number = ST-HL-AE-2608, NUDOCS 8804150368
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 12
}}

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The Light company                               P.O.11ox 1700 llouston, Texa 77001 (713) 228 9211 llouston Lighting & Power April 8, 1988 ST-HL-AE-2608 File No.i G2.4 10CFR2.201 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Response to Violations 8809-04 through 8809-06 Houston Lighting & Power Company has reviewed the Notices of Violation included in Inspection Report 88-09 and submits the attached responses pursuant to 10CFR2.201.
The response provided to Notice of Violation 8809-04 was previously submitted to the NRC by Licensee Event Reports 88-010, 88-011, 88-012, and 88-013. The response provided to Notice of Violation 8809-05 was previously submitted by Licensee Event Report 88-015.
If you should have any questions, please contact Mr. M. A. McBurnett at (512) 972-8530.
bibs             M        g       /
G. E. Vaughn Vice President Nuclear Plant Operations GEV/RAF/ae

==Attachment:==
Responses to Notices of Violation 8804150360 000400 PDR     ADOCK 05000498                                                              \
G                    PDR                                                          O h
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NL.88.085.P2

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llouston Lighting & Power Company ST-HL-AE-2608 File No.:   G2.4   ,
Page 2             '
CCt 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 N. Prasad Kadambi~, Project Manager U. S. Nuclear Regulatory Commission     Dr. Joseph H. Hendrie 1 White Flint North                     50 Be11 port Lane 11555 Rockville Pike                    Be11 port, NY 11713 Rockville, MD 20859 Dan R. Carpenter Senior Resident Inspector / Operations c/o U. S. Nuclear Regulatory Commission P. O. Box 910 Bay City TX 77414 Don L. Garrison Resident Inspector / Construction 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 i
i R. L. Range /R. P. Verret
;                                Central Power & Light Company j                                P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 copies)
!                                Chief Operating Officer l                                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 i
Revised 03/18/88 NL. DISTR.1

Attachment ST-HL-AE-2608 Page 1 of 10 South Texas Project Electric Generating Station                                                      :
Unit 1                                                                        !
Docket No. STN 50-498 Response to Notice of Violation 8809-04                                                         t I. Statement of Violation Implementation of Technical Specification Surveillance Requirements Technical Specification 4.0 states, in part, that surveillance                                                  !
requirements shall be met during the operational modes or other 2            conditions specified for individual limiting conditions for operation.                                          l and that there are surveillance requirements applicable for inservice inspection and testing of ASME Code Class 1, 2, and 3 components.
Contrary to the above, the licensee identified four more cases where technical specification surveillance requirements were not met in spite of efforts to prevent recurrences of similar incidents identified prior to this inspection period in Licensee Event Reports 87-009, 87-019, 87-026, and 88-006. On January 26, 1988, the licensee discovered that k
no periodic surveillance tests had been implemented for the charging header pressure transmitter CV-PT-204, thus rendering the containment isolation capability associated with the charging header inoperable. On January 27, 1988, the licensee discovered that the 11B Essential Chilled                                        i Water Pump inservice test was not accomplished within the required                                              ,
frequency. On January 29, 1988, the licensee discovered that the STP                                          ;
Unit 1 Pump and Valve Inservice Test Plan, Revision 2, f ailed to list                                          -
the required stroke time limits for Valve CV-FCV-0205. On February 4,                                           i 1988, the lic.nsee discovered that the time delay relays in all of the feedwater isolation / turbine trip logic channels had never been                                                ;
j            surveillance tested.                                                                                            j 4                                                                                                                            <
II. Houston Lighting and Power Position Houston Lighting and Power does not contest the violation.                                                      ,
III. Reason for Violation e
A. No Periodic Surveillance Test for CV-PT-204                                                                i A surveillance procedure was not developed for this instrument because it was not addressed in the STP Technical Specifications.
This occurred because the STP Technical Specifications were developed using the Standard Technical Specifications for                                                  ,
Westinghouse plants which do not use this particular instrument loop and was inadvertently overlooked during subsequent reviews for STP unique functions.
i I
This event was reported to the NRC by Licensee Event Report 88-010
.                 dated February 25, 1988 based upon the instrument loop being                                               1
.                 inoperable because pressure transmitter PT-204 could not be                                                ,
calibrated and that this condition was not recognized by the Shift 2                                                                                                                            >
i NL.88.085.P2 i

l Attachment                        :
ST-HL-AE-2608 Page 2 of 10 Supervisor during his review of the Maintenance Work Request                                                        I resulting in required actions not being taken.                                                                     j The program for generation and approval of Maintenance Work Requests was not effective in that sufficient guidance for making decisions                                                 ,
relative to equipment operability was not provided to the shift supervisor.
: 3. Missed Surveillance Test on 11B Essential Chill Water Pump The cause of the event was determined to be inadequate control of the surveillance test package. After the surveillance test package was prepared by the Surveillance Program Scheduler, it was lost during the routing of the package to the main control room. A                                                      l l                                                           contributing f actor to the event was that the missed surveillance test did not appear on the Overdue Report. The method used by the                                                   l Surveillance Coordinator to change the test f requency was flawed.
The method for performing this action was not documented in the                                                   ;
Surveillance Scheduling Procedure.
Another contributing factor to the event was the mode change report
,                                                             used to support the January 25, 1988 mode change showed the wrong                                                 l due date for this surveillance requirement. The surveillance                                                      ;
coordinator had changed the due date without realizing that the past                                              [
due date was in fact valid. The method for controlling the changing                                               ;
of due dates was not documented in the Surveillance Scheduling Procedure.                                                                                                        .
l' This event was reported to the NRC by Licensee Event Report 88-011, dated February 26, 1988.                                                                                          ;
)                                                          C. Missing Stroke Time in Pump and Valve Inservice Test Plan i
The cause of this occurrence was the failure to incorporate revisions to the Pump and Valve Inservice Test (IST) Plan into implementing procedures. This occurred because there was no                                                       ,
administrative requirement in procedure OPGP03-ZE-0021, Inservice i                                                            Testing Program for Valves, to review implementing procedures when
:                                                             the IST Plan is revised. Procedure 1 PSP 03-CV-0011 was not verified to be compatible with revision 1 of the IST Plan when it was issued.
l                                                             This event was reported to the NRC by Licensee Event Report 088-012,
:                                                            dated February 29, 1988.
i I
D. No Periodic Surveillance Testing of Feedwater Isolation / Turbine Trip Logic Channel Time Delay Relays                                                                                   .
I l
The cause of this event was personnel error because during the preparation and subsequent review of the affected surveillance I                                                             procedures the procedure writers and reviewers believed that the                                                  ,
testing procedure described in the vendor technical manual would                                                  e i                                                             include the testing of the low flow time delay relays. This l
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Attachment ST-HL-AE-2608 Page 3 of 10 assumption was made based upon the following statement made in the Periodic Testing section of the vendor manual concerning the low flow test: "The following is a self sufficient test procedure for an individual logic train."    If further research had been conducted it would have revealed that the low flow time delay relays were not addressed.
This event was reported to the NRC by Licensee Event Report 88-013, dated March 4, 1988.
IV. Corrective actions that have been taken Item A - An evaluation of the Maintenance Work Request generation and approval process has been performed. Recommendations resulting from this evaluation are under consideration for incorporation into Station procedures.
Item B - Other cases where the testing frequency was changed based on the tests last performance were verified to have been performed successfully or correctly scheduled. No other problems were found.
On November 23, 1987, Procedure OPGP03-ZE-0004 which describes the Plant Surveillance Program was revised to create the position of divisional Surveillance Coordinators and to give them the responsibility for following surveillance test packages assigned to their divisions. If these controls would have been in place at the time of the November 6, 1987 test, it would have prevented the missed surveillance.
The methodology for changing the test frequency based upon the performance of a previous surveillance as well as the method for approving changes to surveillance due dates have been added to procedure OPGP03-ZA-0055.
Item C - A temporary procedure, 1 TSP 03-CV-0001, correcting the deficient condition was generated and performed satisfactorily, allowing the valve to be declared operable.
The review of revision 2 of the IST Plan was completed no other discrepancies were identified.
Two independent reviews of other pump and valve inservice surveillance tests were performed to ensure agreement of the implementing procedures with the IST Plan. No other discrepancies were identified.
The stroke time limiting value for CV-FCV-0205 was incorporated into revision 3 of the IST Plan which was submitted to NRC on February 5, 1988.
NL.88.085.P2

Attachment ST-HL-AE-2608 Page 4 of 10 An independent review of revision 3 of the IST Plan was performed prior to its submittal to the NRC.
IPSP03-CV-0011, Chemical and Volume Control System Operability Text (Cold Shutdown), has been revised to include provisions for obtaining the open stroke time for CV-FCV-0205.
Item D - Surveillance test procedures were revised, reviewed and approved to test the SSPS actuation train low flow time delay relays.
Other surveillance procedures have been reviewed for similar omissions of testing requirements.
STPEGS procedure OPGP03-ZA-0002, "Plant Procedures," has been revised to require a second, independent, technical review of procedures when written or reviced to ensure accuracy and adequacy.
V. Corrective Actions that will be taken Item A - Program enhancements, recommended by the program evaluation, including more detailed guidance to operating personnel relative to determination of equipment operability will be implemented by April 15, 1988.
A proposed Technical Specification amendment is being developed to add the low charging header pressure instrument loop operability for Limiting Condition for Operation and Surveillance Requirements. This proposed amendment was scheduled for submission to the NRC by April 4, 1988, however because of external influences it is now anticipated that it will be transmitted by May 30, 1988.
A surveillance procedure is being developed to test this actuation function consistent with other Engineered Safety Features (EST) functions and to meet the proposed Technical Specification requirements. It is anticipated that this change can be made by May 15, 1988. The surveillance f requency is
;                        once per 18 months or each refueling.
Item B - Procedure OPGP03-ZE-0004, Plant Surveillance Program, will be further enhanced to require that the divisional Surveillance Coordinators periodically review upcoming tests and ensure that test packages are received by the start date. Thit action will be complete by April 12, 1988.
Item C - OPGP03-ZE-0021. Inservice Testing Program for Valves, will be revised by June 1, 1988 to include controls to review l
implementing procedures when new revisions to the STPEGS Pump l
and Valve Inservice Test (IST) Plan are issued. No new revisions are expected to the IST program before revision to l
this procedure is made.
1 NL.88.085.P2
[

6 Attachment ST-HL-AE-2608 Page 5 of 10 Item D - The STPEGS procedure OPGP03-ZE-0005, "Plant Surveillance Procedure Preparation," will be revised to require che writer to ensure that available information used to document the entire circuit is reviewed to ensure that the circuit being tested by the procedure is physically the circuit req' aired to be tested by the surveillance requirements. This revision will be completed by April 15, 1988.
HL&P believes the added requirement of second independent technical reviews of surveillance procedures and the addition of divisional surveillance coordinators will greatly enhance the effectiveness of the surveillance program.
VI. Full Compliance.
The plant is in full compliance.
NL.88.085.P2

Attachment ST-HL-AE-2608 Page 6 of 10 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Response to Notice of Violation 8809-05 I.                                                           Statement of Violation 8809-05 Implementation of Technical Specification Action Requirements Technical Specification 3.7.1.5 requires the licensee to initiate a cooldown in one hour to reach Hode 4 in the next 6 hours in accordance with Technical Specification 3.0.3 in the event more than one main steam isolation valve becomes inoperable when the plant is in Mode 3.
Contrary to the above, at about 9 a.m. on February 5,1988, the packing glands on two main steam isolation valves were tightened rendering the valves inoperable while the plant was in Mode 3.                                                                          The licensee failed to initiate a cooldown to Mode 4 by 10 a.m. and did not meet the requirement to be in Mode 4 until 2:58 a.m. on February 6,1988, when the plant was cooled down for other, unrelated reasons. Consequently the plant was in a condition prohibited by Technical Specification 3.7.1.5 from about 4 p.m. on February 5, 1988, un'il 2:58 a.m. on February 6, 1988.
II.                                                         Houston Lighting and Power Position Houston Lighting and Power does not contest the violation.
III.                                                         Reason for Violation The root causes of this event were Failure of the Unit Supervisor to recognize that the HSIV's were inoperable due to insufficient familiarity with Technical Specification 3.7.1.5.
Failure of the Unit Supervisor to involve his supervisors in deciding the operability of the valves.
NL.88.085.P2

Atcachment ST-HL-AE-2608 Page 7 of 10 IV. Corrective actions that have been taken The Unit 1 Operations Manager has issued a memo to the Shift Supervi-ors which discusses this event.
Nuclear Plant Operations has implemented a procedure which requires a three party review by the Shif t Supervisor, Unit Supervisor and Shif t Technical Advisor of all LCO actions.
V. Corrective actions that will be taken Intermediate corrective action for this event will be to review the operability requirements for containment isolation valves with Licensed Operators between March 28 and April 29, 1988 during requalification training.
Long Term corrective action will be the evaluation and revision as necessary to the Licensed Operator Training Program to ensure thAt Technical Specifications are taught with emphasis on practical applications. This will be completed by August 31, 1988.
VI. Full Compliance The plant is in full compliance.
I I
l I
l t
l l
l l
NL.88.085.P2 l
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Attachment ST-HL-AE-2608                  -
Page 8 of 10 South Texas Project Electric Generating Station Unit 1 Docket No STN 50-498 Response to Notice of Violation 8809-06 I      Statement of Violation Test Procedure Adequacy and Implementation Technical Specifications 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained as recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978.
Contrary to the above, on January 26, 1988, the licensee failed to reestablish the proper testing configuration as required by the note in Section 4.7 of Station Procedure ITEP07-AF-0010 Revision 0, "Auxiliary Feedwater Proof Test," after interrupting the test to feed steam generators. This resulted in obtaining improper test results requiring a repeat of the test. On February 5,1988, the licensee implemented an inadequate procedure. Station Procedure 1 PEPO 4-ZL-0024, Revision 3, "Rod Drop Time Measurement" did not provide for closing the reactor trip breakers, nor did the procedure provide controls to ensure that the same breakers were opened upon recovering from the test.
II. Houston Lighting and Power Position Houston Lighting & Power does not contest the violation associated with the performance of procedure 1 PEPO 4-ZL-0024 Rod Drop Time Hessurement, but does take exception to the citation relating to the performance of procedure iTEP07-AF-0010, Auxiliary Feedwater Proof Test. The following information is provided in support of this position.
Test procedure 1TEP07-AF-0010, Auxiliary Feedwater Proof Test, was performed to show that modifications to the AFW Flow Control Valves (FCV's) had removed the source of the 24Hz excitation which was respons'ble for system resonant vibration discovered during November 1987. Step 4.7 is an initial condition requiring manually closing of each train's FCV against the mechanical stop. The Single-Train portions of the test then consist of opening the Outside Containment Isolation Valve (OCIV) to esteblish flow to a train's steam generator and observing temporary instrumentation for resonant vibrations while incrementally opening the handwheel of the FCV one turn at a time.
Plant conditions during the testing necessitated that the test be suspended periodically to blowdown to maintain proper steam generator level. This was recognized during the writing of the test procedure, and the following r.ote was added to the Initial Conditions section addressing this need:
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ST-HL-AE-2608 Page 9 of 10 3
s' NOTE The test may be suspended and flow to the Steam Generators terminated by closing the respective Stop-Check OCIV at any time while ATW Pump 12 is operating to prevent exceeding the steam generator high level setpoint (87.5%). The test may start assin at the point of suspension providad the Test Coordinator ensures that appropriate AFW conditions are re-established.
During the test the NRC inspector noticed that the Test Coordinator did not require the FCV of the train being tested to be manually closed against its manual stop prior to restarting the test. The note had been intended to allow the action taken by the Test Coordinator, however the NRC inspector present at the time of test did not agree with this interpretation. To prevent further testing delays the test sequence was exited and started over utilizing the additional actions of manually closirg the FCV and reopenir.g it to its previous position following each test suspe..sion. Contrary to the statement of violation, performing the
 ,                     test using the original interpretation did not, and would not result in invalid test data, for the following reasons:
: 1. The FCV's in the trains not being tested were isolated from the train undergoing tests, by a closed crosstie valve.
j                      2. The FCV in the train being tested romained in the position it was in at the time of the test suspensions only the stopcheck Outside Containment Isolation Valvo was repositioned. This action allowed the steam generator to be blown down to appropriate levels to resume testing.
: 3. Closing the FCV during this process was not necessary for proper system operation, nor was it necessary for personnel protection.
: 4. The action of closing and reopening of the FCV after each test suspension was also undesirable because it unnecessarily lengthened the te'*iSg process.
In summary, Houston Lighting & Power decided to reperform the test in order to eliminate the possibility that the test results would be subject to questions. We do not agree that a proceduran viol. tion occurred.
NL 88.085.P2

Attachment ST-HL-AE-2608 Page 10 of 10 III. Reason for Violation As stated in section II of this response Houston Lighting & Power does not agree that a violation occurred with respect to procedure ITEP07-AF-0010. The following information is provided nagarding procedure 1 PEPO 4-ZL-0024.
The lack of control associated with the reactor trip breakers in procedure IPEPO4-ZL-0024 Rod Drop Time Measurement, was caused by an inadequate review during the generation and approval cycle, in that it was believed that the reactor trip breakers were operated as part of the procedure for starting / securing the Rod Control System Motor Generator sets. If this had been true the prerequisite section would have ensured the breakers closed and the breakers would have been opened when the Shift Supervisors secured the M/G set after being informed that the testing had been completed.
IV. Corrective actions that have been taken Procedure ITEP07-AF-0010, Auxiliary Fe^dwater Proof Test, was suspended when questioned by the NRC inspector and was reperformed utilizing the inspectors interpretation of the Note preceeding step 4.7.
Procedure 1 PEPO 4-ZL-0024, Rod Drop Time Measurement, was changed to incorporate specific steps to control the position of the reactor trip breakers. This was done to provide consistency betwaen various plant procedures.
V. Corrective actions that will be taken No further corrective actions are deemed necessary.
VI     Full Compliance The plant is in full compliance.
1 NL.88.085.P2
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