ML20148B205

Insp Repts 50-498/88-05 & 50-499/88-05 on 880119-22. Deviation Noted.Major Areas Inspected:Licensee Compliance W/ Generic Ltr 81-21, Natural Circulation Cooldown, Involving Safety Issue Mgt Sys Item MPA B-66

ML20148B205
Person / Time
Site:	South Texas
Issue date:	03/11/1988
From:	Gagliardo J, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148B023	List: ML20148B020 ML20148B124 ML20148B205
References
50-498-88-05, 50-498-88-5, 50-499-88-05, 50-499-88-5, GL-81-21, NUDOCS 8803210383
Download: ML20148B205 (4)

See also: IR 05000498/1988005

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/88-05 Operating License: NPF-71

50-499/88-05 Construction Permit: -CPPR-129

Dockets: 50-498

50-499

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

P.O. Box 1700

Houston, Texas 77001

Facility Name: South Texas Project Electric Generating Station (STPEGS),

Units 1 and 2

Inspection At: Bay City, Texas

InspectionCondctep: January 19-22, 1988

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Inspector: \

Datel

InG. A.(yick, Reactor Inspector, Operational

P frams, Division of Reactor Safety

Approved: 30O

V. E. gagliardo, Chief, Operational Programs Date'

Division of Reactor Safety

Inspection Sumary

Inspection Conducted January 19-22, 1988 (Report 50-498/88-05; 50-499/88-05)

Areas Inspected: Routine, announced inspection of licensee compliance with

Generic Letter 81-21, "Natural Circulation Cooldown." This involved safety

issue management systems (SIMS) Item No. MPA-B-66.

Results: In this inspection a weakness was identified in the STPEGS comitment

tracking in that it failed to include and/or recognize that there may be

comitments which remain to be implemented. Specifically, a deviation from

STP's comitment, Confirmatory Item No.11, to use reactor vessel head vents

during natural circulation cooldown was identified.

Additionally, an unresolved item regarding how HL&P plans on altering its

emergency operating procedure writers guide to include comitments was

identified.

8803210383 880315

PDR ADOCK 05000498

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DETAILS

1. Persons Contacted

• G. E. Vaughn, Vice President, Nuclear Operations

• W. R. Kinsey, Plant Manager

• M. R. Wisenburg, Plant Superintendent, Unit 1

• J. R. Walker, Operations Support Manager

• L. G. Weldon, Manager, Operations Training Division

• S. M. Head, Supervisor, Operations Licensing

• P. L. Walker, Licensing Engineer

• L. R. Schlazer, Consulting Engineer

R. L. Templeman, Senior Reactor Operator (SRO)

D. Olson, Consultant

• Denotes those attending the exit interview.

2. Followup of Generic Letter 81-21, "Natural Circulation Cooldown" (25586)

The NRC inspector reviewed information related to Houston Lighting and

Power Compan

Letter (GL)81-21,

y (HL&P) compliance

"Natural Circulationwith its commitments

Cooldown." relative to Generic

The GL required

licensees to develop procedures and provide training on those procedures

to prevent

supplies ofor mitigate reactor

safety-grade vessel

auxiliary voidingAFW)areavailable,and

feedwater (, verify that sufficient

demonstrate by analysis and/or test that a controlled natural circulation

cooldown could be conducted. The STPEGS safety evaluation report (SER)

discusses Confirmatory Item No. 11. The licensee committed to analyzing

the Diablo Canyon natural circulation boron mixing and cooldown testing,

consistent with NRC Branch Technical Position Reactor Systems Branch 5-1

and satisfactorily demonstrate that the results are applicable to STPEGS,

Unit 1.

Correspondence between the NRC and HL&P reviewed regarding this issue is

listed below:

' ST-AE-HL-767, "Natural Circulation Cooldown (GL 81-21)," dated May 5,

1981

ST-HL-AE-1827, "Applicability of Diablo Canyon Natural Circulation

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Test - SER Confirmatory Item Number 11," dated January 21, 1987

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' ST-HL-AE-19 9, "Long Term Cooling: Additional Information (SER Open

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Item Number 16)," dated February 13, 1987

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• ST-HL-AE-1922, "Applicability of Diablo Canyon Natural Circulation

Test - Confirmatory Item Number 11," dated February 23, 1987

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ST-HL-AE-2011, "Natural Circulation (Confirmatory Item 11) Long Term

Cooling-(SER Open item 16)," dated March 30, 1987

During verification of licensee activities related to the generic letter,

the NRC inspector determined that STPEGS Unit I had an E0P, 1 POP 05-E0-ES02,

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Revision 2, "Natural Circulation Cooldown," to conduct a natural

circulation cooldown without creating a void in the reactor vessel head.

Classroom and simulator training was conducted on this procedure. The

licensee calculated the amount of safety grade AFA required to be a maximum

of 377,000 gallons to address a 4-hour hot standby, followed by

approximately a 14-hour natural circulation cooldown. The usable capacity

of the AFW tank is 525,000 gallons.

The NRC inspector reviewed the licensee's procedure for conducting

natural circulation cooldown with saturated corditions in the reactor

coolant system. The licensee committed to cooling the upper head and

enhance mixing by utilizing the reactor vessel upper head vent (UHV)

systen. Supplement 3 of the STPEGS, Unit 1 SER discusses the HL&P

comitments contained in correspondence dated February 13, 1987

(Si-HL-AE-1909), February 23, 1987 (ST-HL-AE-1922), and March 30, 1987

(ST-HL-AE-2011). Confirmatory item No. 11 approval was based on the

comitments in the above mentioned correspondence.

The emergency procedure,1P0P05-E0-ES03, Revision 2, "Natural Circulation

Cooldown With Steam Void in Vessel," used to conduct a natural circulation

cooldown with saturated conditions in the reactor coolant system utilized

pressure control without use of the UHV. This E0P failed to meet the

comitment described above; therefore, this is an apparent deviation of

the licensee's comitnent to utilize the UHV system. (498/8805-01)

From discussions with HL&P employees, the NRC inspector determined that

it was not clear to them that the comitment was to be included as

part of the emergency prccedures along with guidance contained in the

Westinghouse Owners Grcup Emergency Response Guidelines (WOG ERG). The

NPC inspector was informed that items on the Nuclear Plant Operations

Department (NP0D) management action tracking system (MATS) were to be

reviewed for applicability. Licensee commitments were not defined as a

source of suoport documents in the development of E0Ps as specified in

Procedure OPOP01-ZA-0006, Revision 3, "Emergency Procedures Writer's Guide

and Verification," although the WOG ERGS were. The NRC inspector will

follow up, in a subsequent inspection, the actions taken by HL&P to assure

that the E0P writer's guide has sufficient guidance to ensure that all

comitments pertaining to E0Ps are incorporated into their emergency

procedures and actions taken by NP0D to assure that all emergency

procedure commitments had beer, incorporated. (0 pen Item 498;499/8805-02)

The NRC inspector determined that HL&P has a site tracking system for

commitments and requirements, the licensee comitment tracking system (LCTS).

Since the MATS is internal to NP00, there is no assurance all commitments

in LCTS pertaining to NPOD were included in the MATS.

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After identification of the above deviation (498/8805-01), the licensee

took corrective action to revise Emergency Operating Procedure IP0P05-E0-ES03,

to include the missed commitments. The licensee also. proposed corrective

actions to determine whether other commitments may not be included in the

LCTS, HL&P plans to sample the LCTS and determine whether their commitments,

as identified in the sample, were actually implemented. Secondly, it

plans on verifying that all commitments contained in correspondence from

HL&P to NRC dated June 1986 to present were included on the LCTS and any

commitments, if not included, are to be added. This issue is related to a

concern expressed in the cover letter of NRC Inspection Report 50-498;499/87-77

on the adequacy of the commitment tracking system to routinely provide

management with an accurate status of connitments made by HL&P. This

issue will remain open (0 pen Item 498;499/8805-03) and will be reviewed

following the licensee's response to NRC Inspection Report 50-498;499/87-77.

The NRC inspector confirmed that a startup test procedure,1P0P04-ZX-0010,

Revision 1, "Natural Circulation Verification," was developed and that it

verified establishment of natural circulation as committed to in FSAR

Chapter 14.2.12.3, "Test Description 13."

The NRC inspector confirmed through discussions with the licensee that

it had instrumentation at the emergency shutdown panel to assure natural

circulation cooldown in the event the control room became uninhabitable.

The instrumentation utilized is the same as that in the control room, the

Qualified Dispicy Processing System and Emergency Response Facility

Data Acquisition Display System computer display.

No other violations or deviations were identified.

3. Exit Interview

The scope of the inspection and findings were discussed with those people

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identified in paragraph 1. The licensee did not identify as proprietary

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any of the materials provided to or reviewed by the NRC inspector during

the inspection.

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