ML20148K715

Discusses 871230 Enforcement Conference Re Findings of Insp Repts 50-498/87-71 & 50-499/87-71 on 871101-30.Meeting Summary Encl.Meeting Beneficial

ML20148K715
Person / Time
Site:	South Texas
Issue date:	01/19/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
EA-87-240, NUDOCS 8801280025
Download: ML20148K715 (17)

See also: IR 05000498/1987071

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In Reply Refer To:

Dockets: 50-498 M !O N

50-499

EA 87-240

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Houston Lighting & Power Company

ATTN: J. H. Goldberg, Group Vice

President, Nuclear

P.O. Box 1700

Houston, Texas 77001

Gentlemen:

This refers to the enforcement conference conducted in the NRC Region IV

office on December 30, 1987, with you and other members of your staff and

Region IV staff members to discuss findings of'the NRC inspection conducted

during the period of November 1-30, 1987, which were documented in NRC

Inspection Report 50-498/87-71; 50-499/87-71, dated December 18, 1987.

The topics covered are described in the enclosed meeting summary.

It is our opinion that this meeting was beneficial and provided a

better understanding of the concerns identified during the inspectiori.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter will be placed in

the NRC's Public Document Room.

Should you have any questions concerning this letter, we will be pleased to

discuss them with you.

Sincerely,

Original Signed By

L J. Callan

L. J. Callan, Director

Division of Reactor Projects

Enclosure:

Meeting Suntnary

cc:

Houston Lighting & Power Company

ATTN: M. Wisenberg, Manager

Nuclear Licensing

P.O. Box 1700

Houston, Texas 77001

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Houston Lighting and Power Company 2

Houston Lighting & Power Company

ATTN: Gerald E. Vaughn, Vice President

Nuclear Operations

P.O. Box 1700

Houston, Texas 77001

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Central Power & Light Company

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

P.O. Box 2121 '

Corpus Christi, Texas 78403

City Public Service Board

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

P.O. Box 1771

San Antonio, Texas 78296

City of Austin

ATTN: M. B. Lee /J.-E. Malaski

P.O. Box 1088

Austin, Texas 78767-8814

Texas Radiation Control Program Director

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bec distrib. by RIV:

• DRP *RRI-0PS-

R. D. Martin, RA *RRI-CONST. '

Section Chief (DRP/D) RPSB-DRSS

• RIV File

• Lisa Shea, RM/ALF *RSTS Operator

R. Bachmann, 0GC *H. Bundy ,

• P. Kadambi, NRR Project Manager *R. Taylor

• DRS D. Powers

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MEETING SUMMARY - DECEMBER 30, 1987

Licensee: Houston Lighting and Power Company (HL&P).

Facility: South Texas Project (STP), Units 1 and 2

Dockets: 50-498 Operating License: NPF-71

50-499 Construction Permit: CPPR-128

Subject: Enforcement Conference

Concerning NRC Inspection Findings (HRC Inspection

Report 50-498/87-71; 50-499/87-71) and Related Concerns

On December 30, 1987, representatives of HL&P met with NRC Region IV and NRR

personnel in the NRC office in Arlington, Texas to discuss the findings

documented in NRC Inspection Report 50-498/87-71; 50-499/87-71, dated

December 18, 1987. Other recent events of mutual concern were also

discussed. The attendance list and summary of the licensee presentatice are

attached. The meeting was held at the request of the NRC, Region IV.

The licensee discussed root causes for selected events, corrective actions

taken to preclude recurrence, and results achieved to-date.

The NRC staff expressed particular concern regarding the two events discussed

below:

a. Plant Entered Mode 4 on October 31, 1987, with High Head Safety Injection

(HHSI) System Valves Shut

The licensee agreed that this was the most serious of the events selected

for discussion. There was no direct safety impact because the reactor

core has not been operational and no decay heat was present. Accordingly,

the major NRC concern was with regard to the evident weaknesses in the

licensee operating practices which allowed this condition to continue for

51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br /> prior to discovery. Many operators, supervisors and managers had

opportunities to question the off-normal valve positions during this

period.

b. Pressurizer Pressure-Low Trip Septpoint Was Set lass Conservatively than

Technical Specification (TS) Requirement on November 24, 1987

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This setpoint error had the effect of rendering all four. channels of the

safety injection actuation system inoperable. The staff questioned the

efficiency of the licensee's procedure review and approval process in

allowing the incorrect setpoint to be inserted in the procedure. This

setpoint had been changed as result of engineering analysis by the vendor

and HL&P had requested the TS change as a result of this analysis. NRC

Inspection Report 50-498/87-27 discussed this change as a followup to HL&P

Incident Review Committee Item 333. Also NRC Inspection Report 50-498/

87-39, Open Item 498/8739-10, identified specific TS setpoint errors for

annunciators and suggested further verification of instrument setpoints.

Despite these references and subsequent TS audits performed by the

licensee, the setpoint error was not corrected prior to entry into Mode 3.

Another concern the NRC staff had was the fact that HL&P in Licensee Event

Report (LER)87-017, dated December 21, 1987, failed to recognize the  ;

change to Mode 3 with incorrect setpoints as a TS violation. This point

was clarified in the meeting.

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The NRC staff explained to licensee representatives the enforcement policy.

The licensee was commended for his candor in reporting and discussing the

above described events.

Attachments:

A. Enforcement Conference Attendance

B. Outline of HL&P's Presentation

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Attachment A

Enforcement Conference Attendance

December 30, 1987

Name Title Organization

J. H. Goldberg Group VP Nuclear HL&P

G. E. Vaughn VP Nuclear Operations ' 'HL&P

W. H. Kinsey Plant Manager, STP HL&P

-M. Wisenburg Manager, Engineering & Licensing HL&P

M. A. McBurnett Manager, Operations Support HL&P

Licensing

L. Joe Callan Director, Division of Reactor NRC, RIV

Projects

J. L. Milhoan Director, Division of Reactor NRC, RIV

Safety

A. Bill Beach Deputy Director, Division or NRC, RIV

Reactor Projects

H. L. Scott Enforcement Staff NRC, RIV

G. L. Constable Chief, Reactor Projects Section D NRC, RIV-

D. M. Hunnicutt Chief, Test Programs Section NRC, RIV

M. T. Hardt Director, Nuclear Division City Public Service

San Antonio

D. R. Carpenter Senior Inspector-STP NRC, RIV

H. F. Bundy Project Engineer NRC, RIV

N. P. Kadan61 Project Manager NRC, NRR

J. 1. Tapia ProjectEngineer(SectionA) NRC, RIV

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SOUTNTEHR$

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PROJECT

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NRC ENFORCEMENT CONFERENCE ,

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i ARLINGTON, TEXAS

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DECEMBER 30,1987 i

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AGENDA

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e Introduction - J. H. Goldberg

e Technical Specification - W. H. Kinsey

Violations

e Management initiatives - W. H. Kinsey

e Questions / Answers

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EVENT

e Plant entered Mode 4 on 10-31-87 with HHSI system valves isolated.

• Discovered during shift tumover on 11-02-87.

e immediately opened Train "B" and "C" valves.

ROOT CAUSE

e Poorly planned evolution. Operations Management in effort

to verify plant lineup did not understand procedural relationships

and operator performing evolution did not understand "big picture."

CORRECTIVE ACTION

e Remedial training for operators and management on compliance with

procedures, selection of procedures, proper planning and attention to detail.

• Revise specific involved procedures and review others for

similar weakness.

O Enhance shift tumover information on status of Safety Related equipment.

e Simulator training with emphasis on mode changes and accompanying

requirements.

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EVENT

e Plant staff discovered that Reactor Containment Building (RCB)

Atmosphere monitor 1-131 channel was not tested in accordance with

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technical specifications on 09-18-87.

e Grab sampling of RCB initiated and the channel tested within

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ROOT CAUSE

e Process for review of last minute technical specification changes

and incorporation of technical specifications into surveillance procedures

was not ngorous. Management relied on responsible individuals to perform

last minute changes without verification.

CORRECTIVE ACTION

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e Review technical specification surveillances and LCO numbers,

with exception of ESF and RTS setpoints, against surveillances.

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e implementation of future technical specification changes will be

performed using a detailed process that incorporates independent verification.

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EVENT

e Plant staff discovered Pressurizer Pressure-Low Trip Setpoint was

set less conservatively than technical specification requirement on 11-24-87.

• Plant conditions required for function never achieved.

e Instruments recalibrated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ROOT CAUSE '

e Process for review of last minute technical specification changes

and incorporation of technical specifications into surveillance procedures  !

was not ngorous. Management relied on responsible individuals to perform

last minute changes without verification.

CORRECr1VE ACTION

e Review Engineered Safety Features and Reactor Trip System

setpoints against surveillance procedures to ensure no other items

were missed.

e implementation of future technical specification changes will be ,

performed using a detailed process that incorporates independent verification.

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EVENT

e Plant staff discovered that the slave relay contact for train "A"

containment spray actuation was not tested on 11-24-87.

• Performed test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ROOT CAUSE

e Superficial review of procedure field change and absence of written

interpretation of technical specification requirements.

CORRECTIVE ACTION

e Reviewed trains "B" and "C" to ensure identical error was not made.

e Remedial training for I&C Division Supervision on independent

verification of procedure changes and on attention to detail.

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EVENT

e Plant staff discovered the 4160 degraded voltage and the degraded

voltage coincident with safety injections contacts were not tested

on 12-12-87.

• Performed tests within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

ROOT CAUSE

e Technical preparation and independent review were not rigorous.

Absence of written interpretation of technical specification requirements.

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CORRECTIVE ACTION

e Established station policy on relay testing.

• Performed two independent reviews of al! I&C and electrical

surveillance tests for compliance with technical specifications.

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EVENT

e Plant staff discovered both toxic gas monitors out of service

on 12-06-87.

• Placed control room in recirculation mode and restored monitors to

service.

ROOT CAUSE

e insufficient supervision and training of reactor operator student

conducting routine log readings.

C_ORRECnVE ACTION

e Conduct Plant Operations and Chemical Operations staffs crew

briefings, stressing importance of conducting thorough indoctrination /tmining

for students. Reemphasize responsibility for student actions.

• Reprogram toxic gas monitors such that operators are only required

to read computer printouts to perform channel operation checks.

e Review and revise OJT training program for operator rounds.

• Review and revise operator logs for channel check recording requirements.

• Complete technical specification equipment "positive statusing" review.

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EVEXT

e NRC Resident insp'ector informed Plant Manager that, contrary to

commitment, "A train Auxiliary Feedwater cross-connect volve was not

tagged closed when plant entered mode 3.

ROOT CAUSE

e Insufficient written guidance and training provided to shift

personnel on implementation of "Night Order" assignments.

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CORRECnVE ACTION

. e Revise "Night Order" administrative procedure and train shift

! personnel on changes.

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EVENT

e Two fire protection dampers were found to be blocked open with

electrical tie wraps and wire. These dampers were designed to be held

open with fusible links.

• Fire watches immediately established in affected areas.

ROOT CAUSE

o Uakown. Quality assurance records indicate adequate installation.

No evidence can be found of maintenance or in situ testing on the affected

dampers following installation.

CORRECTIVE ACTION

e One damper has been restored to full service. Other damper is

still inoperative awaiting replacement parts.

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MANAGEMENT INITIATIVES

O PLANNED

e Executive management briefings with all supervision and management

• Additional review of recent plant startup events

e increase emphasis on use of simulator for normal evolution training

• Peer involvement on personnel error investigations

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e Root cause determination training for representative Department personnel

e Continued high level management involvement in Station Operation

/ Plan of Day Meetings

/ Station Problem Reports

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