ML20148M652

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/88-01 & 50-499/88-01

ML20148M652
Person / Time
Site:	South Texas
Issue date:	03/24/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8804060057
Download: ML20148M652 (2)

See also: IR 05000498/1988001

Text

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MAR 2 41988 l

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In Reply Refer To:

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Dockets: 50-498/88-01 1

50-499/88-01

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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 March 1,1988, in response to our letter and l

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Notice of Violation dated February 10, 1988. 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 8

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to determine that full compliance has been achieved and will be maintained.

Sincerely,

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Original Signed By

A. B. Beach

1

h J. Callan, Director

j. Division of Reactor Projects i

cc: .

Houston Lighting & Power Company l

ATTN: M. A. McBurnett, Manager  !

Operations Support Licensing

P.O. Box 289

Wadsworth, Texas 77483

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Houston Lighting & Power Company -2-

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cc: (cont'd)

Houston Lighting & Power Company

ATTN: Gerald E. Vaughn, Vice President

Nuclear Operations

P.O. Box 1700

Houston, Texas 77001

Houston Lighting & Power Company

ATTN: S. L. Rosen

P.O. Box 289

Wadsworth, Texas 77483

Central Power & Light Company

ATTN: R. L. Range /R. P. Verret

P.O. Box 2121

Corpus Christi, Texas 78403

City Public Service Board

ATTN: R. J. Costello/M. T. Hardt

P.O. Box 1771

San Antonio, Texas 78296

City of Austin Electric Utility

ATTN: R. J. Miner, Chief Operating

Officer

721 Barton Springs Road

Austin, Texas 78704

Texas Radiation Control Program Director

bec:

bec to DMB (IE01)

bec distrib. by RIV:

DRP RRI-0PS

R. D. Martin, RA DRS

SectionChief(DRP/D) RPSB-DRSS

MIS System RIV File

Lisa Shea, RM/ALF RSTS Operator

R. Bachmann 0GC D. Hunnicutt

P. Kadambi, NRR Project Manager TSS

D. Powers

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The Light

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company PO. Bos 1700 Houston, Texas 77001 (713) 228 9211

ilouston Lighting & Power

, March 1, 1988

ST-HL-AE-2541

File No.: G2.04

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U. S. Nuclear Regulatory Comission

Attention: Document Control Desk

Washington, DC 20555

South Texas Project Electric Generating Station

Unit 1

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Docket No. STN 50-498

Response to Violatiens 8801-01 through 8801-08

HL&P has reviewed the Notices of Violation included in inapection Report

88-01 and submits the attached responses pursuant to 10CFR Part 2.

If you have any questions, please contact Mr. M. A. McBurnett at

(512)972-8530.

Wy

G. E. Vaughn

Vice President

Nuclear Plant Operations

GEV/WH/kr.

Attachment: Responses to Notices of Violation

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MAR 2 2

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A Subsidiary of Houston Industries' incorporated

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CT-HL-AE-2541

File No.: G2.04

Page 2

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Regional Administr,ator Region IV Rufus S. Scott

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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 Nanager

U. S. Nuclear Regulatory Commission INPO

1 White Flint North Records Center

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11555 Rockville Pike 1100 Circle 75 7'Tkway

Rockville. MD 20859 Atlanta. Ga. 30339-3064

Dan R. Carpenter

Senior Resident Inspector / Operations

c/o*U. S. Nuclear Regulatory

Commission

j 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 76403

R. John Miner (2 copies)

Chief Operating Officer

City of Austin Electric Utility

721 Barton Springs Road

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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 02/03/88

NL.LER. DISTR.1

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ST-HL-AE-2541

Page 1

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A. Statement of Violation 8801-01:

Hich Head Safety Iniection Pump Controls System Lineup

Technical Specification 6.8.1 requires that written procedures be

established, implemented, and maintained covering the activities

recommended in Appendix A of Regulatory Guide 1.33. Revision 2. February

1978. Section 3 of this appendix recommends procedures for operation of

I the emergency core cooling system.

Procedure IPOP02-SI-0002. Revision 6 dated December 30. 1987 Safety

Injection System Initial Lineup. has been established in accordance with

Technical Specification 6.8.1 to implement. inter alia. Technical

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Specification 3.5.3.

Contrary to the above, on January 7. 1988, the NRC inspector found that (

this procedure was not adequate to control the alignment of the high head

saf ety injection pumps in Mode 4. Forms 3. 7. and 11. providing the

i Mode 4 alignment of saf ety injection system Trains A. B. and C.

respectively, specified the required position for the high head saf ety

injection pump main control board handswitches to be "PTL" (Pull to

Lock). Following this procedure would have made all three high head

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saf ety injection pumps inoperable in Mode 4. contrary to Tectoical ,

Specification 3.5.3.

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Reason for violation

The root cause of this violation was inadequate review of the procedure  ;

to assure its consistency with the requirements of the applicable

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Technical Specifications.

' Corrective actions that have been taken: ,

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1. Procedure IPOP02-SI-0002 has been revised to correct Forms 3, 7. and

11 to indicate the proper handswitch alignments for all modes.

2. A review of other system lineup procedures was performed to ensure

i their consistency with the Technical Specifications.

3. Procedure OPGP03-ZA-0002 has been revised to incorporate requirements 7

for an independent technical review of new procedures. l

Corrective actions that will be taken: 5

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No f urther action is required.

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Full Compliance l

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ST-HL-AE-3541

Page 2

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B. Statement of Violation 8801-02: ,

Temporary Modifi ca ti ons i

Technical Specification 6.8.1 requires that written procedures be

established, implemented, and maintained covering the activities

recommended in Appendix A of Regulatory Guide 1.33. Revision 2.

February 1978.

Procedure OPGP03-ZO-0003. Revision 7. dated September 12. 1987

"Temporary Modifications and Alterations." has been established in

accordance with this Technical Specification.

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Section 4.7 of this procedure requires that the control room hard copy of

piping and instrumentation drawings affected by a temporary modification

I be annotated and clouded in red to identify the existence of a temporary

modification. It further requires that a copy of the temporary

modification request be attached to the drawing and a notation of which

' drawings were updated to be made on the original of the temporary

modification request.

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Contrary to the above, on January 5, 1988. the NRC inspector found that  !

l the requirements of Section 4.7 of Procedure OPGP03-ZO-0003 had not been l

. met f or Temporary Modification TI-EV-87-252 f or Drawing 5R289F05038 in

that no markup had been made.

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j Reason for violationt

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The root cause of this violation was the Systems Engineer's lack of

attention to detail in following the procedure. A contributing factor

was a lack of positive controls (e.g., signature verifications) on the 1

Temporary Modification Request (THR) form to ensure compliance with the

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procedure. Another contributing factor was a lack of clarity in the . '

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procedure with regard to the treatment of blank and blind flanges. [

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i Corrective actions that have been takent

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1. Drawing 5R289F05038 was updated in compliance with procedure

OPGP03-ZO-0003 (i.e., red lining of drawing, attaching a copy of the

TMR. noting drawing update)

2. A review of outstanding temporary modifications was performed against l

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the requirenehts of the procedure. Identified discrepancies were

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Attechnent

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3. Procedure OPGP03-ZO-0003. Temporary Modifications and Alterations, j

was revised to clarify treatment of blank and blind flanges. The j

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< procedure was also revised to implement the following additional

controls:

a. Identification of Key Drawings on the' Temporary Modification f

Request.

$ b. Addition of a confirmation signature indicating that the affected i

drawing (s) have been red lined.  ;

j c. Addition of a restoration signature indicating that the drawings

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have been restored to normal after temporary modification is '

removed.

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4. System Engineers have been formally advised of the procedural changes j

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and the requirement to follow them in detail.

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Corrective action that will be taken $

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i No further action is required.  ;

Full Compliance

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The plant is in full compliance. l

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ST-HL-AE-2541

Page 4

C. Statement of Violatior 8801-03:

Locked Valves

Technical Specification 6.8.1 requires that written procedures be

established, implemented, and maintained covering the activities

recommended in Appendix A of gegulatory Guide 1.33. Revision 2.

February 1978. Section 3 of this appendix recommends procedures for

operation of the emergency core cooling system.

Procedure 1 POP 02-SI-0002. Revision 6. dated December 30, 1987 "Safety

Injection System Initial Lineup." has been established in accordance with

this Technical Specification.

Form 9 of this procedure. Initial Lineup Train C. requires Manual Valves

SI-0059C. SI-0224C. ar.d SI-0070C to be locked closed.

Contrary to the above on January 6. 1988, the NRC inspectors found that

SI-0059C was closed, but not locted and that SI-0224C and SI-0070C were

closed but inadequately locked. The cables and padlocks on these latter

two valves could easily be removed by hand.

Reason for violation:

The root cause of the violation was lack of attention to detail on the

part of operations personnel who inspect valves in accordance with the

Locked Valve Program in that inadequately locked and/or unlocked valves

were not identified and corrected in accordance with the Locked Valve

Program OPGP03-20-0027.

Corrective actions that have been taken:

1. Valves SI-0070C and SI-0224C were locked and valve SI-0059C was

tagged as allowed by procedure.

2. valves required to be locked in accordance with the Locked Valve

Program were inspected for proper position and locking devices or

administrative controls. None were found to be improperly

positioned. Those that were found to be inadequately locked were

either properly locked or administrative controls were implemented

through the station clearance process.

Corrective actions which will be taken

No further action is required.

Full Compliance

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The plant is in full compliance.

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NL.88.053.03

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ST-HL-AE-2541

Page 5

D. Statement of Violation 8801-04:

Containment Intecrity

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Technical Specification 3.6.1.1 requires that containment integrity be .

maintained in Modes 1. 2. 3. and 4. The conditions of license

regulation. 10CTR50.54 invokes Appendix J to 10 CTR 50 to define

containment integrity and to limit combined leakage measured by test, to

less than 0.6 La.

Contrary to the above the licensee was in Mode 4 on October 31 and

Fovember 1. 1987. With Containment Isolation Valve BIRAMOV0003. not

tested for local leak rate after maintenance so that the ability to moet

the 0.6 La criterion was not determined.

Reason for violation:

The root causes of the event were determined to be:

1. Failure to provide maintenance planners and maintenance supervisors

with adequate training concerning post maintenance testing (PMT)

requirements regarding containment integrity.

2. Failure to identify the appropriate PMT requirements f or local leak

rate testing on the MVR during supervisory review.

Corrective actions that have been taken:

1. A Local Leak Rate Test was satisf actorily performed on the subject

valve and it was returned to an operable status at approximately 2200

hours on January 6. 1988.

2. A review c,' MVRs and LLRT records was conducted to ensure that proper

testing had been done to assure containment integrity.

3. Informatica regarding this event was discussed with maintenance

supervisory personnel and maintenance planners. The intent of these

briefinjs was to make these personnel aware of the importance of

maintaining containment integrity. Maintenance planners were advised

to discuss PMT requirements with the cognizant system engineer prior

to issuang a MWR. especially in regards to containment isolation

valves.

4. To enhance the current MVR program. NWR procedure. OPGP03-ZM-0003.

was revised to assure that the required PMTs are identified on MVRs

involving containment isolation valves.

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NL.88.053.03

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Attachment ,

ST-HL-AE-2541

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Page 6

Corrective action that will be takent

' Training of shift supervisors and support personnel will be conducted to '

reinforce the importance of post-maintenance testing with regard to -

containment integrity requirements.

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Full Compliance ,

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The plant will be in full compliance upon completion of the training.

This is expected to be done by March 3 1988. ,

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ST-HL-AE-2541

Page 7

E. Statement of Violation 8801-05:

Surveillance Procedure Discrepancies

Criterion V of 10 CTR 50. Appendix B. requires, in part, that activities

'

'affecting quality be performed in accordance with approved drawings,

insttuctions, and procedures appropriate to the activity.

The licensee's approved Operations Quality Assurance Plan. Section 112.

"Test Control." Paragraph 6.4 requires that test procedure shall provide

instructions for performing tests and provisions for documenting results.

Contrary to the above, the licensee failed to follow procedures

associated with the Surveillance Program and/or failed tp provide

adequate procedure to control the activities affecting the quality of

Technical Specification surveillance as identified in the six examples

cited below: ,

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1. In December 1987 the licensee collected 250 milliliter waste liquid i

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discharge samples in lieu of the one liter samples required by

Procedure 1 PSP 07-WL-0001.

2. On January 7. 1988, it was f ound that Procedure OPSP07-CR-0002 was (

inadequate in that it failed to provide the necessary requirement to

calculate an average sample. Chemistry Technicians were observed to

be calculating the average sample in accordance with verbal

instructions in lieu of following the procedure.

3. On January 6. 1988, it was found the Procedures 1 PSP 02-RC-0454. 0461.

and 0462 had been improperly modified by Field Change Request to

waive Stegs 7.4.2 and 7.7.16 when reactor coolant temperature is

below 538 F in that the data sheet was not modified to support the

change.  ;

4. On January 7, 1988, it was found that Procedure OPSPO4-XC-0001

Revision 1. had been improperly revised such that changes were

incorporated into an unapproved draf t of Revision 0 in lieu of an

approved copy of Revision O. resulting in a Revision 1 that contained

j draft errors. This is contrary to the requirements of

OPGP03-ZA-0002. Revision 10. "Plant Procedures."

5. On January 6 1988, it was found that Procedure 1 PSP 11-RH-0004

Revision 1. failed to contain numeric values of the acceptance

criteria due to a series _of inappropriate char.ges. This is contrary

to the requirements of OPGP03-ZE-0005. Revision 6. "Plant

Surveillance Procedure Preparation." Section 3.2.6.

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l 6. On January 6 1988, it was found that two completed surveillance test

packages for OPSPO4-DG-0001 were presented to the Plant Operations

Review Committee (PORC) for acceptance of the results based on ,

previously accomplished preoperational test information with missing ,

data. 7he packages were approved by the PORC with missing data.

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ST-HL-AE-2541

Page 8

Reason for violationt  !

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Item I was attributable to poor judgement by technicians who decided to

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substitute a different size container for the size specified in the

procedure.

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Item 2 was attributable to inadequate description rf required

calculations in the procedure.

Items 3. 4. and $ were attributable to a f ailure to follow procedures

regarding the use of FCRs.

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Item 6 is attributable to two factorst

1. Personnel reviewing the pre-operational test package prior to its

presentation to PORC failed to detect a copying error.

2. The level of review performed by PORC vas not of sufficient detail

and depth to detect the copying error.

Corrective actions that have been takent

Item 1: Chemical Analysis personnel have been reinstructed regarding

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the importance of f ollowing procedures verbatim.

Item 2: Chemical Analysis surveillance procedures requiring

calculations have been reviewed and revised as necessary to

ensure that adequate instruction on performance of the

calculations is provided.

Items 3-5 A Departmental bulletin was issued providing additional

guidance to NPOD personnel regarding the control of Field

Change Request changes to surveillance procedures.

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Procedure OPGPO3-ZA-OOO2 "Plant _ Procedures" was revised to

include specific guidelines for the review and implementation

of Field Change Requests.

Item 6: The data missing from the subject packages was reviewed and

approved by PORC and inserted in the file packages,

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An ISEG special investigation was conducted to review the PORC

process to recommend possible enhancemente. The

recommendations, which wele issued February 22. 1988 include

more formal control of the PORC meetings, more control of

"walk-on" items, better definition of s: ope of review.

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ST-HL-AE-2541  ;

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Corrective action that will be takent  ;

Management will review the ISEG recommendations and identify any [

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improvements and a schedule for implementation by March 31, 1988.

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Full Compliance l

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The plant is in full compliance, however, enhancements to the PORC

process may be made following review and analysis of the ISEG report.

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ST-HL-AE-2541

Page 10

F. Statement of Violation 8801-06:

Implementation of Technical Specification Eeauirements

Technical Specification 6.8.1 requires that written procedures shall be . 1

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established, implemented, and maintained covering activities recommended  ;

in Appendix A of Regulatory Guide 1.33. Revision 2. February 1978.

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Contrary to the above, it was found on January 7.1988, that the licensee

had failed to provide test procedures, which completely implemerted the

final technical specifications as cited below:

1. Procedure 1 PSP 10-RC-0001. Revision 0, contained an acceptance

criterion calling for a figure in the technical specifications which

had been deleted when the final technical specifications were issued.

thus resulting in an incomplete and inadequate procedure for

conducting the surveillance. l

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2. Procedure OPSP10-II-0003 was found to contain an incorrect and

nonconservative equation for adjusting the core radial peaking factor [

limit f or f ractional power levels, thus resulting in an incorrect and

inadequate procedure conducting the surveillance.  !

Reason for violations f

The root cause of this violation was that the process to incorporate

changes in the T9chnical Specifications into procedures did not track I

required actions to completion. t

Corrective actions that have been takent .

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1. OPSP10-II-0003 has been corrected to be consistent with the .4chnical  ;

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Specifications. Procedure 1 PEPO 4-ZG-0007 has been identified as the '

proper procedure for use in RCS flow measurement in lieu of

IPSP10-RC-0001. I

2. Suf ficient review of surveillance procedures has been completed to

assure compliance with Technical Spec 2fication requirements for

operation through Mode 2.

3. Procedure OPGP03-ZA-0002 has been revised to require an independent

techn* cal review of new procedures. Requirements have beeb added to

the procedure to perform a "walk through" of new surveillence

procedures to confirm the Frecedure can be accomplished as written.

Additional procedure review criteria have been imposed by means of an

uttribute check sheet which includes items for confirming Technical

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Specification requirements.

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4. Interdepartmental procedure 3.20Q is now in ef f ect which requires

Technical Specification changes to be tracked f rom request through

implementation. It also requires a QA verification of implementation.

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NL.88.053.03 .

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Corrective action that will be taken ,

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Suf ficient review of surveillance procedures to assure that Mode 1  !

Technical Specification rrquirements are incorporated will be completed [

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prior to exceeding % power. .

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The plant is in compliance f or operation through Mode 2. Confirmation of

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full compliance will be achieved upon completion of the remaining reviews j

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ST-HL-AE-2541

Page 12

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G. Statement of Violation 8801-07:

Overdue Station Problem Report Investigation

Criterion V of Appendix B to 10 CPR Part 50 and the licensee's approved  ;

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quality assurance plan require that activities affecting quality be

conducted in accordance with approved procedures. Interdepartmental

Procedure IP 1.45Q. "Station Problem Reporting." requires that corrective

investigations be completed within 17 days.

,

l Contrary to the above, on January 4 1988. 68 of 204 station problem

i reports were overdue (past 17 days) for completion.

1

1- Reason for the violationt

U

The root cause of the violation was inadequate assignment of resources to

prioritize and resolve the SPRs.

.

Corrective actions that have been taken I

.

o

1. The safety significance of each SPR is evaluated when the SPR is

I first initiated, and immediate action is taken if required to assure

plant safety. A review was performed which confirmed that the

l

conditions described in the open SPRs have been adequately addressed

' so that plant saf ety is not adversely af fected.

2. Revision 1 of Procedure 1.450 was implemented on February 22, 1988.  !

This new procedure increased management's involvement in the process

by requiring an early establishment of priority and due date by the

'

Plant Manager. The revision also requires the SPR originator to take

the SPR directly to the Shif t Supervisor.

3. . Additional licensing engineers have been assigned to coordinate

resolution of SPRs. These personnel have participated in a concerted

i

effort to resolve overdue SPRs. The backlog of overdue SPRs has been

reduced to an acceptable level.

{

I

Correction action that will be tatent

No further action is required.

Full Compliance:

The plant is in full compliance.

.

,

h

!

NL.88.053.03 ,

1

, . - _. __

_

.'.* Attcchtsnt

ST-HL-AE-2541

Page 13

H. Inadecuate corrective Action (8801-08):

' Criterion XVI of Appendix B to 10 CFR Part 50 and the licensee's approved

quality assurance plan require conditions adverse to quality be proeptly I

identified and corrected. In August 1987, a quality assurance audit

[

deficiency' report was issued wh4ch identified 55 of 179 station problem

reports were overdue for completion. The deficiency was closed on the

basis that tracking responsibility for station problem report ,

investigation tracking was procedurally changed.

Contrary to the above, it was found on January 4, 1986, that the

corrective action was not adequate in that 68 of 204 station problem

,

reports were overdue for completion.

Reason for the violation:

As noted in the statement of the violation, the backlog of overdue SPRs

was identified in an audit in August 1987, and as corrective action

procedures were changed to assign responsibility for coordination of SPRs

to Licensing. Nuclear Assurance accepted this response and a follow up

audit to determine the effectiveness of the corrective action was

scheduled for February 1988. Prior to the follow-up audit, management

failed to identify that the corrective action had not been effective.

Corrective actions which have been taken:

.

In accordance with the schedule adopted upon acceptance of the response

to the August 1987 audit, in February 1988 Nuclear Assurance completed

its follow-up audit of the effectiveness of the ccrrective actions. The

,

follow-up audit identified inadequate effectivenesr, of the earlier

corrective action as a significant deficiency (DR S87-064. Rev.1).

l

J

Response to DR 587-064. Rev. 1 is due by March 18. 1988. The response to

! DR S87-064. Rev. I will be reviewed by Nuclear Assurance.

The corrective actions described in response to Notice of Violation

88 01-07 have been implemented. and are expected to resolve DR S87-064.

,

l

Rev. 1. As an interim measure, until management gains added confidence

in the effectiveness of the revisions to the SPR program. Licensing is

providing management with weekly reports of SPR status.

Corrective actions that will be taken:

As a result of the DR. a review of Station Problem Reports is being

conducted to assure that root causes were adequately addressed and that

supporting documentation properly dispositions the required actions.

This activity is expected to be complete by 60 days after the issuance of i

.

the Full Power operating License.

.

Full Compliance:

The plant will be confirmed to be f ull compliance utan completion of the

SPR review described above. ,

.

NL.88.053.03

(

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