IR 05000498/1987008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/87-08 & 50-499/87-08

ML20216H125
Person / Time
Site:	South Texas
Issue date:	06/24/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8707010289
Download: ML20216H125 (2)

Text

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In Reply Refer To: j

Dockets: 50-498/87-08 50-499/87-08 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President, Nuclear P. O. Box 1700

Houston, Texas 77001 Gentlemen: )

Thank you for your letter of June 12, 1987, in response to our letter and i

NoticeofViolation(498/8708-02) dated May 29, 1987. We have reviewed your j i

reply and find it responsive to the concerns raised in our Notice of Violatio I We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine l'

Sincerely, a ,eui c:zo.1 mi

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J. E. Gagliardo, Chief Heactor Projects Branch cc:

Houston Lighting & Power Company ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Houston Lighting & Power Company ATTN: Gerald E. Vaughn, Vice President Nuclear Operations P. O. Box 1700 8707010289 e70624 Houston, Texas 77001 DR ADOCK 0500 ja Texas Radiation Control Program Director bec: (see next page)

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June 12, 1987 ST-HL-AE-2238 File No.: G CFR2.201 l

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U. S. Nuclear Regulatory Commission )

Attention: Document Control Desk Washington, DC 20555 South Texas Project l Units 1 and 2 1 Docket Nos. STN 50-498, STN 50-499 l Response to Notice of Violation 8708-02 Failure to Follow Procedures for Performing Tes Houston Lighting & Power Company has reviewed Notice of Violation

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. 498/8708-02 dated May 29, 1987, and submit the attached response pursuant to 10CFR2.20 If you should have any questions on this matter, please contact M S. M. Head at (512) 972-8392, i l

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G. E. Vaughn Vice President, Nuclear Plant Operations WPE/mg Attachments: 1.) Response to Notice of Violation 498/8708-02 2.) Response to 10CFR50.55(e) dated April 29, 198 I'

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ST-HL AE-2238 Houston Lighting & Power Company File No.: G Page 2 cC; Regional Administrator, Region IV . M.B. Lee /J . E. Malaski Nuclear Regulatory Commission City of Austin 611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX 76011 Austin, TX 78767-8814 N. Prasad Kadambi, Proj ect Manager A. von Rosenberg/M.T. Hardt Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771  :

Bethesda, MD 20814 San Antonio, TX 78296 l Robert L. Perch, Proj ect Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l 7920 Norfolk Avenue 1717 H Street Bethesda, HD 20814 Washington, DC 20555 Dan R. Carpenter )

Senior t'.asident Inspector / Operations c/oU.SkNuclearRegulatory Commis s f:on P.O. Box 910 Bay City, TX 77414 Claude E. Johnson Senior Resident Inspector / Construction c/o U.S. Nuclear Regulatory Commission

P.O. Box 910 Bay City, TX 77414

M.D. Schwarz, Jr. , Esquire '

Baker & Botts One Shell Plaza Houston, TX 77002 ,

J.R. Newman, Esquire Newaan & Holtzinger, L Street, Washington, DC 20036 T.V. Shockley/R.L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 76403

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L4/NRC/fp/mg-0 Revised 2/3/87

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Attachment 1 l

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ST-HL-AE 2238 File No.: C Page 1 of 2

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l South Texas Project Units 1 and 2  ;

Docket Nos. STN 50 498, STN 50-499 Response to Notice of Violation 8708-02 Failure to Follow Procedures for Performing Tes I. Statement of Violation

" Criterion V of Appendix B to 10CFR50, requires that activities affecting quality be prescribed by documented instructions or procedures, and shall be accomplished according to these procedures. The STP-Operations Quality Assurance Plan implements this requirement for operations. Final 3 Safety Analysis Report (FSAR) Section 14.2.4.4, states 'The person j conducting the test is charged with overall responsibility for performing l the test in accordance with the approved test procedur If, during the

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performance of the test, it is determined that the test cannot be conducted as written, it is the responsibility of the person conducting the test to suspend testing until the procedure has been modified and approved.'

" Contrary to the above, on March 11, 1987, while performing the Unit 1 Hot Functional Test (HFT) under the subtier Preoperational Test 1-RH P-04

for the RHR system, the Startup Test Director verbally instructed the operator to perform different steps than those required by the )

preoperation test, which the operator then performe Subsequently, the '

operator was performing the evolution under 1-RV-RH-236 in support of the Preoperational Test 1-RH-P-04 and skipped two steps in the procedur The above two actions led to a water hammer event in Trains "B" and "C" of the component cooling water (CCW) system; resulting in structural damage to the Train "B" CCW syste II. Reason for Violation The reason for the violation was operator error which occurred while initiating Residual Heat Removal (RRR) System operation. The test procedure in use was a modified version of the normal operating procedure for RHR System initiation. The test procedure did not clearly identify the status of the RHR heat exchanger CCW discharge valves during the preliminary phases of the test. Verbal direction from the Startup Test 4 Director led to closure of the CCW discharge valves which increased the 1 potential for waterhammer in the CCW system. In addition, the operator failed to close the RHR system discharge valves prior to the tes III. Corrective Actions Taken and Results Achieved The corrective actions which STP has taken to resolve this violation have been detailed previously in our 10CFR50.55(e) report of April 29, 198 (ST-HL-AE-2034, Attachment 2). An update of these corrective actions j follow i

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Attachment 1

ST-HL-AE-2238 File No. G Page 2 of 2 l

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The damaged portions of the adversely affected pipe supports have been replaced as required. The damaged pressure safety valve (PSV) has been replace At this time, all corrective actions are complet IV. Corrective Steps Taken to Prevent Recurrence As with the actions in item III above, the corrective steps which STP has taken to prevent recurrence were described in our prior 10CFR50.55(e)

report. An update of these recurrence control measures follow l Operator training on plant procedures for RHR initiation and operation, l as well as for the loss of RHR, have been completed in the Operator Requalification Training Program. Training of licensed operators in the power ascension procedures (including classroom training and simulator sessions) has been included in the operator training program and is l ongoin V. Date of Full Compliance STP is in full compliance at this tim l l

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.,' '* Attachment 2 to ST-HL-AE-2238

. The Light i NE Houston Lighting 8: Pow 1 P.O. Bos 1700 flausson, has 77001 i7136 228 9211

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l April 29, 1987 ST-HL-AE-2034 File No.: C12.372, G CFR50.55(e)

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Final Report Concerning Water Hammer in Unit 1 CCW Lines On March 12, 1987, Houston Lighting and Power Company notified your '

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. . office pursuant to 10CFR50.55(e), of an item concerning a water hammer event in Unit 1 Component Cooling Water (CCW) lines. Enclosed is our Final Report i on this item. An extension of the submittal date of this report, to April 29, i 1987, was granted by G.L. Constchle on April 24, 1987. We have determined that this item is reportable pursuant to 10CFR50.55(e). -

If you should have any questions on this matter, please contact I Mr. C. A. Ayala at (512) 972-862 )

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J. H. Goldberg Group Vice President, Nuclear j MB/hg l Attachment: Final Report Concerning Water Hammer in Unit 1 CCW Lines i

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, Attachment 2 to ST-HL-AE-2238 ST HL-AE-2034 I ' '

Houston Lighting & Power Company ' '

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Regional Administrator, Region IV M.B. Lee /J.E. Malaski I Nuclear Regulatory C/mmission *

City of Austin 611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX 76011 Austin, TX 78767-8814 N. Prasad Kadambi, Project Manager A. von Rosenberg/M.T. Hardt U..S. Nuclear Regulatory Commission City Public Service Board j 7920 Norfolk Avenue P.O. Box 1771 Bethesda, MD 20814 San Antonio, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 H Street Bethesda, KD 20814 Washington, DC 20555 Dan R. Carpenter Senior Resident Inspector / Operations c/o U.S. Nuclear Regulatory Commission j P.O. Box 910 l Bay City TX 77414 1 i

Claude E. Johnson Senior Resident Inspector /STP c/o U.F. Nuclear Regulatory Conmission

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P.O. Box 910 Bay City, TX 77414 M.D. Schwarz, Jr., Esquire Baker & Botts One Shell Plaza Houston, TX 77002

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J.R. Newman, Esquire Newman & Holtzinger, L Street, k'ashington, JDC 20036 T.V. Shockley/R.L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403

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L4/NRC/wh/hg-2 . Revised 2/3/87 i

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Attachment 2 to ST-HL-AE-2238 l (.* *

Attachment ST-HL-AE-2034

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File N G12.372, C Page 1 of 3

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South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50 499 Final Report Concerning Wacer Hammer in Unit 1 CCW Lines I. Summary On March 12, 1987, Houston Lighting and Power (HL&P) notified the NRC, pursuant to 10CFR50.55(e), of a reportable item concerning a water hammer event in Unit 1 Component cooling Water (CCW) lines. This event damaged supports and piping in the CCW system and occurred as a result of operator error while initiating Residual Heat Removal (RHR) system operation. This item is considered reportable pursuant to 10CFR50.55(e) .

II. Description of Deficiency

The water hammer event occurred while initiating operation of RHR trains B and C during the final stages of The reactor coolant system conditions were 350,F hot andfunctional 350 psig.testin The following three phases are required to initiate RHR system operation: Establish recirculation path of RHR fluid through the RHR heat exchanger to equalize the boron concentration; -

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• Establish a reactor coolant recirculation path bypassing the RHR ,

heat exchanger; I l Establish flow through the RHR heat exchanger to begin cooldown of the reactor coolant syste The source of cooling water to the RHR heat exchangers is the Component Cooling Water System (CCW). Normal operating procedures require CCW initiation prior to establishing RHR flow through the RHR heat exchanger The test procedure in use was a modified version of the norm,a1 operating procedure for RHR initiation. This test procedure did not clearly identify the status of the heat exchanger CCW discharge valves during phase 1 and phase 2. At the start of phase 3, these valves are to be opened to establish CCW flow prior to commencing reactor coolant flow through the heat exchange At the verbal direction of the Test Director, the CCW discharge valves were closed to expedite RHR heat up for both trains prior to phase 1. In this configuration, there was no CCW flow through either heat exchange The train B CCW pump was subsequently stopped to maintain minimum flow requirements for the train C CCW pum The water hammer event occurred as a result of the operator failing to close the heat exchanger RHR discharge valves prior to phase 1 as required by procedure. This resulted in reactor coolant flow through the RHR heat exchangers during phase Since CCW flow was not established, steam voids were formed in both train L4/NRC/wh/hg-2 ,

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