IR 05000498/1992026

Ack Receipt of 921113 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/92-26 & 50-499/92-26

ML20126C476
Person / Time
Site:	South Texas
Issue date:	12/16/1992
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hall D HOUSTON LIGHTING & POWER CO.
References
NUDOCS 9212230081
Download: ML20126C476 (4)

Text

e kQ 400 UNIVED STATES

• o 0 g NUCLEAR REGULATORY COMMISSION

-$ o REGION IV 2, o E 611 RY AN PLAZA DRIVE, SUITE 400 Y, f AR LINGTON, TEXAS 76011-8064

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DEC I 61992 Docket Nos. 50-498 50-499 License Nos. NPF-76 NPF-80-Houston Lighting & Power Company ATTN: Donald P. Hall, Group Vice President, Nuclear P.O. Box 1700 Houston, Texas 77251 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NO. 50-498/92-26; 50-499/92-26 Thank you for your letters of November 13, 1992, in response to our letter and Notice of Violation dated October 16, 1992. We have reviewed ycur replies and find them responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine whether full compliance has been achieved and will be maintaine

Sincerely, f / ,, f 44 n --.

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. Bill Beach, irctdrs Division of Reac r Projects cc:

Houston Lighting & Power Company ATTN: William J. Jump, Manager Nuclear Licensing P.O. Box 289 Wadsworth, Texas 77483 City of Austin Electric Utility Department ATTN: J. C. Lanier/M. B. Lee i1 P.O. Box 1088

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Houston Lighting'& Power Company -2-City Public Service Board ATTN: R. J. Costello/M. T. Hardt P.O. Box 1771 San Antonio, Texas 78296 Newman & Holtzinger, P. ATTH: . Jack R. Newman, Es L Street, NW Washington, D.C. 20036

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Central Power and Light Company ATTN: D.-E. Ward /T. M. Puckett P.O. Box 2121 Corpus Christi,- Texas 78403 INP0 Records Center

. 1100 circle 75 Parkway Atlanta, Georgia. 30339-3064 Mr. Joseph M. Hendri Bellport Lane Bellport, New York 11713 Bureau of Radiation- Control State of Texas 1101 West 49th Street Austin, Texas 78756

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Judge, Matagorda County Hatagorda County Courthouse-1700 Seventh Street Bay City,-Texas 77414 -

Licensing Representative-Houston Lighting & Power Company Suite 610

• Three Metro Center Bethesda, Maryland 20814 Houston Lighting & Power Company ATTN: Rufus S. Scott, Associate General Counsel P.O. Box 61867 Houston, Texas 77208

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Houston Lighting & Power Company DEC 161992-bec to DMB (IE01)

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J. L. Milhoan- Residen'; Inspecto DRP Section Chief.(DRP/0).

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Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer.-(DRP/D)- R. Bachmann, 0GC, MS: 15-B-1E DRS Section Chief-(DRP/TSS)--

G. F. Sanborn, E0- J. Lieberman, OE,~MS: 7-H-5; dh RIV:DRP/D(jab C:DRP/D M A d :DitP MASatorius;df ATHowel1 [ ',-ABBeach-12/ lls /92 12/ b/92 l 12//b /92

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5-t The Light c o mp a n ySouth Texas Project Electric Generating Station Box 289 Wadsworth. Texas 77483 Ilouston I.ighting & Power . - - . _ - _ . - - _ _ - - - - -

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G02.04 i~, j 10CFR2.201

L_ _} r l F;EO!ON IV U. S. Nuc1'e'dr 7egulatory Cotimission Attention

Document Control Desk Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50-498 Reply to Notice of Violation 9226-04 Regarding Failure to Document Completion of Work Performance Ilouston Lighting & Power Company (HL&P) has reviewed Notice of Violation 9226-04 dated October 16, 1992, and submits the attached reol If you have any questions, please contact Mr. C. A. Ayala at (512) 972-8628 or me ab (512) 972-792 W. H. Kir e , J Vice Pres ont Nuclear Generation RAD /ag Attachment: Reply to Notice of Violation 9226-04 l

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• H'ouston Lighting & Power Company e ST-HL-E-South Texas Project Electric Generating Station File No.: o ,o4 Page 2 cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Conpany Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager U.S. Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 Circle 75 Parkwaj J. I. Tapia Atlanta, GA 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P. Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, Texas Department of Health 1615 L Street, West 49th Street Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett Central Power and Light Company O. Box 2121 Corpus Christi, TX 78403 C. Lanier/M. Lee City of Austin Electric Utility Department P.O. Box 1088

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Austin, TX 78767 K. J. Fiedler/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 k

Revised 10/11/91

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UNITED STATES OF AMERICA-NUCLEAR REGULATORY-COMMISSION--

In the Matter )

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Houston Lighting & Power ) Docket Nos. 50-498 ,

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South Texas Project )

Unit 1 ) .<

AFFIDAVIT *

= W. H. Kinsey, Jr., being duly sworn, hereby deposts.'and,says that he is Vice President, Nuclear . Generation of Houston Lighting. &

Power Company; that he'is-duly authorized'_to sign:and file.with _

the Nuclear-Regulatory Commission the attached reply to_-NRC Notice-of Violation 9226 .04; that he is familiar with the content thereof;

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and that the matters set forth therein are true and correct to the-best of his knowledge and-belie >

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, W.'H'.-K:.nsey, GJ . :

Vice President, Nuclear Generation-i-.

STATE OF TEXAS }

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Subscribed and sworn to before.me a Notary Public in and for The' State of Texas this /{ day of p$17d (fL/ -, 1992.

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d CONNIE MONTCOMEW

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ST-HL-AE-4251 Page 1 of 2 Statement of Violation: +

Failure to Adecuatelv Document Work Comoletion Technical Specification 6.8. requires. .that written procedures shall be established, implemented, and maintained covering those activities recommended in Appendix A of Regulatory Guide 1.33, Revision- 2, . February 197 Paragraph 9.a of Appendix A requires that maintenance that can affect the performance of safety-related equipment.should be properly proplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstance This is accomplished, in part, by Procedure OPGP03-ZA-0010, Revision 15, " Plant Procedure Adherence and Implementation and Independent Verification."

Step 4.2.19 of Procedure OPGP03-ZA-0010 states that,

" Procedure steps with signoff blanks SHAI4 be signed' or initialed, as appropriato, as soon as practical after th action has been perfarmed."

Contrary to the above, on Septamber 7,1992, Steps 3.02, 3.03, 3 04, and 3.05 of Service Request RC-173817, were not signed off after the action had been performed by the work performer even though ths work verifier had signed off on the corresponding signoff blank This is a Severity level IV violatio (Supplement I)

(498/9226-04)

I Houston Lichtinc & Power Position:

..u&P concurs that the cited violation occurre III. Reason for Violation:

The cause of this event was that the technician did not fully i undarstand management expectations regarding the need to cignoff work performance as soon as practical after the action was performe I Corrective Actions:

The following actions are being taken: A plant bulletin was issued reiterating the requirements to signoff, check or initial work performance as soon as practical after a. procedure action is performe IR\02-303.002

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I Attachment LI-HL-AE-4251 Page 2 of 2 I Corrective Actions: (Con't) Operations,-Maintenance, Plant Engineering and Technical Services Management will provide a briefing paper to _their first line supervisors regarding the need to signoff, check or initial work performance as soon as practical after the action is performed. The briefing papers will include examples where it is impractical to signoff, check or initial work performance immediately after the action is performe This action will be completed by December 4, 199 . First line supervisors in Operations, Maintenance, Plant Engineering and Technical Services will discuss management's expectations with their personnel regarding the need to signoff, check or initial work performance as soon as practical after the action is performed. This action will be completed by December 18, 199 .- Management's expectations will be incorporated into training lesson plans for Work Control which is provided to Maintenance personnel, including new employees and contractor Management's expectations. will be incorporated into lesson plans for Administrative Procedures which is provided to licensed and non-licensed operators, including new personne These actions will be completed by December 31, 199 pate of Full Compliance:

HL&P is in full compliance at this_ tim Briefings will be conducted by December 18, 1992 to ensure that plant personnel understand management's expectations.

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November 13,-1992 ST-HL-AE-4254 File No.:. G02.04 10CFR2.201 U. S. Nuclear Reguletory Commission Attention: Document Control Desk Washington, DC 20555 _

South Texas Project Unit 1 & 2 Docket Nos. STN 50-498, STN 50-490 Reply to Notice of Violation 9226-02 Recardine Failure to Maintain ~Adecuate Procedures Houston Lighting & Power Company (HL&P) has reviewed Notice of Violation 9226-02 dated October 16, 1992, and submits _ the attached repl If you have any questions, please contact Mr. C. A. .Ayala at (512) 972-E628 or me at (512) 972-792 b'hi

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W. H. Kinseh, J Vice President Nuclear Generation

.J\D/ ag AttachmaTt: Reply to Notice of Violation '26-02 727772Pirsy y W Of3-03+fi 1R\92-307.002 A Subsidiary of }{ouston industries incorporated

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H.ouston Lighting & Power Company ST-HL-AE-4254

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. South Texas Project Electric Generating Station File No.:-G02.04-Page 2 Cc!

Regional Administrator, Region IV Rufus.S.-Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company-

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Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager Uuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 Circle 75 Parkway I. Tapia Atlanta, GA- 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph-M. Hendrie Commission 50 Bellport Lane P. O. Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau'of Radiation Control Newman & Holtzinger, Texas Department of-Health 1615 L Street, West 49th Street-Washington, DC 20036 Auchin, TX 78756-3189 D. E. Ward /T. M. Puckett Central Power and Light Company P. O. Box 2121 Corpus Christi, TX 78403 C. Lanier,/M. B. Lee City of Austin Electric Utility Department P.O. Box 1088 Austin, TX 78767 K. J. Fiedler/M. T. Hardt City Public Service Board P. O. Box-1771 San Antonio, TX 78296

Revised 10/11/91 L4/NRC/

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter )

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Houston Lighting & Power ) Docket Nos. 50-498 Company, et al., ) 50-499

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South Texas Project )

Unit 1 and 2 )

AFFIDAVIT H. Kinsey, Jr., being duly sworn, hereby deposes and says that he is .Vice President, Nuclear Generation, of Houston Lighting & Power Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached reply to the NRC Notice of Violation 9226-02; that he is familiar with the content thereof; and that the matters set.-forth therein are true and correct to the best of his knowledge and belie W. H. Kinse)C)J Vice President, Nuclear Generation STATE OF TEXAS )

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Subscribed and sworn to before mc, a Notary Public in and for The State of Texas this /30-day of g3ycg})gp , 199 [P m e n r.terx = 2:c r v.x re.rq 3 . ,

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Attachment ST-HL-AE-4254 Page 1 of 4 Statement of Violation:

Failure to Have Procedures Annropriate to the CircumE,tannqn Technical Specification (TS) 6.8.1.a requires that written procedures shall be established, inplemented, and maintained covering those activities recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,- Februar$' 197 CFR 50, Appendix b, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances. Three examples of violating _

this requirement are stated below: RG 1.33, Appendix A, Itam 8.b(d) , recommends specific procedures for surveillance testing of containment-heat -

and radioactivity removal system This is' accomplished, in part, by Surveillance Procedures 1- and 2 PSP 03-HC-0001, Revision 2, " Reactor Containment Fan Cooler Operability."

Contrary to the above, these procedures were inappropriate to the circumstances because they did 'not provide _

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appropriate guidance to prevent an inadvertent .ESF actuatio Concequently, on August 8, 1992, while implementing Procedure 1 PSP 03-HC-0001, an inadvertent automatic start of a Unit 1 component cooling water pump occurred during the implementation of this procedur . RG 1.33, Appendix A, Item 8.b(1), recommends specific tests and calibrations of the reactor protection syste This is accomplished, in part, by Procedures (1 and-2)

PSP 06-RC-0005, "Undervoltage Reactor Coolant Pump Trip-Actuating Device- Operational Test," and (1 and 2)

PSP 06-RC-0006, "Underfrequency Reactor Coolant Pump Trip Actuat:Ing Device Operational Test.'

contrary to the above, those procedures were inappropriate to the circumstances because they did not provide guidance for verifying the operability of the bistable nonitoring lights for the undervoltage and underfrequency relays.-

Consequently, on August 26, 1992, the licensee discovered that they-had not been complying with TS Surveillance Requirement 4.3.1.1, Table 4.3-1, Functional Units 15 and 16 since April 199 m s2-ao7.co2

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.ST-HL-AE-4254 Page 2 of_4 Statement of Violation: (Con't) RG 1.33, Appendix A, Item 3.s(3), recommends procedures for direct current emergancy . power sources. 'This is accomplished, in part, by Procedure IPOP02-EE-0001, "ESF Class 1E DC Distribution System."

'ontrary to the above, Procedure 1 POP 02-EE-0001 was:

determbad to be inappropriate to ' the circumstances because Step 7.1.8.2 provided instructions to ensure that battery charger voltage is maintained between ~125 and 135 volts direct current. The TS minimum terminal voltage for a battery on a float charge is 129 volts direct curren On September 11, 1992, the terminal voltage for Battery ElB31 was Jess than 129 volts direct current while the battery was on a float charge.-

This is a Severity Level IV violatio (Supplement I)

(498;499/9226-02)

I liouston Lichtina & Power Position:

HL&P concurs that the cited violations occurre II Reason for Violation: The cause of the inadvertent component cooling water pump start was inadequate procedural guidance. The procedure (1 PSP 03-PC-0001) stated only to establish flow and did not identify possible actuations or prevention for those actuati?ns.

, The bistable status monitoring lights were not-verified to be operable during the performance of the Reactor Coolant Pump (RCP) Undervoltage and Underfrequency Trip Actuating Device Operability Test (TADOT)- procedures because Field Changes (FCs) -to the procedures were initiated in April 1990, to remove the requirement from the procedure acceptance criteri The writers and authorities who approved the FCs did not identify the need to verify that the lights were operable as required by Technical Specification 4.3. This was . due- to an inadequate understanding of the definition of a TADOT by the individuals involve A contributing factor was tha procedure OPGP03-3A-0002 " Plant Procedures" which controls-the use of FCs allowed the acceptance criteria to be changed without providing acceptable guidance to the procedure writers and authoritie IRi92-307.002

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Attacnment ST-HL-AE-4254 Page 3 of 4 III. Reason for Violation: (Con't) Following successful completion of the ElB11 Battery Charger 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> load verification (1 PSP 06-DJ-0006) required by Technical Specification 4.8.2.1.c.4, the battery charger was returned to service by Operations personnel using procedure 1 POP 02-EE-0001 "ESF Class 1E DC Dist.ribution System". Procedure 1 POP 02-EE-0001 incorrectly specified that battery charger voltage should be verified to be greater than 125 VD In addition, 1 PSP 06-DJ-0006 did not have provisions to ensure that the as left battery charger voltage was greater than 129 VD A contributing cause was that the low voltage alarm was set at 11*1 VDC, well below Technical Specification limit I Corrective Actions:

The following actions arc being taken:

' (2) PSP 03-HC-0001 wa:a revised to require the operator to place the pump modo selector switches f>r all trains in of f during the surveillance to ensure no inadvertent pump starts occu A caution was also added concerning Reactor Containment Fan Cooler load requirement Additional procedures were identified and revised to incorporate the mandatory mode selector switch settings.-

l This event and recent similar events will be covered in Licensed Operator Requalification trainin Training will be completed by March 26, 199 The TADOT procedures were revised to verify operability of bistable status monitoring lights in the acceptance criteri A clear definition of TADOT has been formally docunented and training on this definition has been provided to appropriate plant personne OPGP03-ZA-0002 " Plant Procedures" will be revised to control the use of FCs for changing acceptance criteria-by November 30, 1992.

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Attachment ST-HL-AE-4254 Page 4 of 4 I _qorrective Actions: (Con't)

2 HL&P discovered the procedural inadequacies of the TADOT procedures during an indepth review of procedures that'

implement the surveillance' requirements of Technical-Specification Tables 4.3-1 (Reactor Protection System) and 4.3-2 (Engineered Safety Feature Actuation System) . Thi review was performed as a result of corrective actions for Licensee Event Report 92-004 ' (Unit 3). The review was completed by the Surveillance Review Task Force on October _

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30, 199 (2) POP 02-EE-0001 has been revised to specify that battery charger voltage is verified to be greater than or equal to the Technical Specification minimum value of 129 VD <

u 3 (2) PSP 06-DJ-0006 will be revised to ensure that the as left battery charger voltage is greater than 129 . VDC following completion of the surveillance tes This will be completed by December 31, 1992, prior to performance of the surveillance on the Unit 2 battery charger The alarm setpoint will be revised to indicate that battery bus voltage is below the Technical Specification minimum valu This will be completed by March 31, 1993, in both Unit HL&P will perform an evaluation of surveillance procedure 4 quality b'1 January 22, 1993, to determine whether a surveillance s prccedure upgrade is necessary to improve station performance in this are Operations Surveillance Procedures (PSP 03 series) have been revicwed to ensure that safety related equipment manipulations are properly controlled in order to reduce unplanned ESF actuation In addition, System Operating Procedures (POP 02 series) are currently being reviewed to ensure that the procedures contain sufficient guidance to properly perform the subject task The review of POP 02 procedures is scheduled to be completed by December 31, 1993, as part of the Operations Procedure enhancement progra As an interim measure, operations personnel complete a procedure review and feedback form whenever any. operations procedure is performed to ensure that the procedures provide. necessary guidanc This will continue until Operations Management is satisfied that procedure weaknesses have been identifie Any significant problems identified are promptly corrected.

> Date of Full Compliance:

HL&P is in full compliance at this tim IR\92-307.002

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Houston Lighting & Power Company -3-DEC ;l 61992 i bec;to DMB;(IE01);

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J. L. Milhoan Resident inspector -

ORP Section Chief (DRF/D)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Proja '. Engineer (ORP/0) R. Bachmann, OGC, MS: 15-B-18 DRS Section Chief (DRP/TSS)-

G. . . Sanborn, EO J. Lieberman, OE, MS: 7-H-5 t

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