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NW 151990 |

Docket Nos. 50-498/90-2850-499/90-28

License Nos. NPF-76NPF-80

IHouston Lighting & Power Company .ATTN: Donald P. Hall, Group

Vice President, NuclearP.O. Box 1700Houston, Texas 77251

Gentlemen:

Thank you for your letter of October 17, 1990, in response to our letter i

and Notice of Violation dated September 18, 1990. We have reviewed your- reply

and find it responsive to the concerns raised in our Notice of Violation

(498/9028-01;499/9028-02). We will- review the implementation of your.

corrective actions during a future inspection to determine that full compliance

has been achieved and will be maintained.

Sincerely,.

/5/. Samuel J.. Collins, DirectorDivision of Reactor. Projects ,

cc:Houston Lighting & Power CompanyATTN: M. A. McBurnett, Manager

Operations Support LicensingP.O. Box 289Wadsworth, Texas 77483

City of. Austin- ,

Electric Utility DepartmentATTN: J. C. Lanier/M. B. LeeP.O. Box 1088'Austin, Texas 78767

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Houston Lighting & Power Company -2-!r. 4

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City Public Service BoardATTN: R. J. Costello/M. T. HardtP.O. Box 1771-San Antonio, Texas 78296

Newman & Holtzinger, P. C.ATTN: Jack R. Newman, Esq.- 1

1615 L Street, NW,

>

Washington, D.C. 20036 !

Central Power and Light Company - !,

ATTN: R. P. Verret/D. E. Ward t

P.O. Box 2121|- . Corpus Christi, Texas 78403

iINP0Records Center .' 41100_ Circle 75 Parkway .Atlanta, Georgia- 30339-3064 ,

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Mr. Joseph M. Hendrie50 Bellport Lane.Bellport, New York 11713

Bureau of Radiation Control *

State of Texas1101 West 49th StreetAustin, Texas 78756

i- Judge, Matagorda CountyMatagorda County Courthouse'

1700 Seventh. Street. Bay City, Texas 77414

Licensing RepresentativeHouston Lighting & Power CompanySuite 610Three Metro Center

. Bethesda, Maryland 20814|

Houston- Lighting & Power :Conpany :*ATTN: Rufus S. Scott, Associate , ,

s

General CounselP.O. Box 61867 o

Houston, Texas ~77208

bec to DMB (IE01) w/ licensee ltr.

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Ibec distrib. by RIV w/ licensee 1tr.:R. D. Martin Resident InspectorDRP SectionChief(DRP/D) ;,

DRS MIS SystemDRSS-FRPS Lisa Shea, RM/ALF ,

RIV File R. Bachmann, OGCRSTS Operator Project Engineer (DRP/D).

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I) T' October 17, 1990'

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~ ! g g g g j !;l ST HL.AE 3596;

hj{ Filo No.: C02 04- ;.

b n b-- ..- - 1D| 10CFR50.73'

-..], U. S. Nuclear Regulatory Commission

Attention: Document Control DeskVashington, DC 20555 !

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. !

South Texas Project Electric Generating Station-Unit 1

Response to Notice of Violations 9028 01 Land 19028 02Failure to Follow Procedures.'for . Independent

Verification and Failure to Provide-Adecuate Accentance Criteria

Houston Lighting & Power has. reviewed the Notices of Violations issued jas a result of NRC Inspection ' Report 90 028 dated September.18,1990, and. !

| submits the attached responses,i J

Notice of Violation 9028-01 occurred during the post trip recovery f'

. effort for Unit 1 LER 90 006.. The response for' this violation is completely - '

covered in the attached LER 90 006 regarding a manual reactor trip due:to full' )closure of'a WIV -during partial.' stroke testing. l

!

-If you should have any questions on this-matter, please contact |

Mr. A. K. Khosla-at (512) 972 7579 or myself at (512) 972 8530. '

I1

M. A. McBurnettManager.Nuclear. Licensing

AKK/sgs,

i Attachment: Reply to Notices of Violations'9028 01.and 9028 02'

IIR 90 006 (South Texas, Unit 1)

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A1/01L N18' A Subsidiary oI Houston Industrics Incorporated

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llouston Lighting & Power Compan)- File No.:002.04South Text. Proj,ect Electric Generat og Stat.ion Page 2.

|cc:

Regional Administrator, Region IV Rufus=S.= ScottNuclear Regulatory Commission Associate General Counsel (

611 Ryan Plaza Drive, Suite 1000 ' Houston Lighting & Power Company .'

Arlington, TX 76011 P. O. Boi 61867Houston, TX 77208

Coorge Dick, Project ManagerU.S. Nuclear Regulatory Commission INPO ;

Washington, DC 20555 Records Center v

1100 circle 75 ParkwayJ. I. Tapia Atlanta, GA 30339 3064Senior Resident Inspector ..

,

c/o U. S. Nuclear Regulatory Dr. Joseph M.L Hendrie:Commission 50 Bellport Lane-

P. O. Box 910~ Bellport, NY .11713Bay City,1D( 77414

D. K. Lacker ,

J. R. Newman, Esquire Bureau of Radiation ControlNewman & Holtzinger, P.C. Texas Department of Health1615 L Street, N.W. 1100 West 49th StreetWashington, DC -20036. Austin, TX 78756 3189

R. P. Verret/D. E. WardCentral Power 6 Light CompanyP. O. Box 2121Corpus Christi, TX 78403

J. C. Lanier/M. B. LeeCity of AustinElectric Utility DepartmentP.O. Box 1088Austin, TX 78767

R. J. Costello/M. T. HardtCity Public Service BoardP. O. Box 1771San Antonio, TX 78296

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-Revised 10/08/90

L4/NRC/,

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AttachmentST.HL.AE.3596

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Page 1 of 3

j 1. Statement if Violations:,

1. Failure to rollow Procedures for indenendent verificarica* t

10 CPR Part $0, Appendix B Criterion V, requires, in part, that *

activities affecting quality be accomplished in accordance with; documented instructions,

,

i Plant Procedure 1 PSP 03. AF.0001, Revision 6, " Auxiliary FeedwaterPump 11 Inservice Test,' Step 5.13,1, states, 'CLost and LOCK TestLine Isolation Valve AF0040 and initini Data sheet ( 2),' and Step

*5.13.2, states 'As a (sic) independent verification have a secondindividual verify Ar0040 is CLOSED And LOCKED and initial .Seta4

'

Sheet ( 2). >

' *

Plant Procedure OPOP03 20 0004, Revision 11, ' Plant Conduct ofOperations,* Step 4.4.11, requires that independent verificationsshall be performed as prescribed by approved procedures or' ,atructions in accordance with OPCP03.ZA.0010, " Plant ProcedureCompliance, Implementation, and Reviews '

Plant Procedure OPCP03.ZA.0010, Revision 11, * Plant ProcedureCompliance Implementation, Review,' Step 3.3.2.1, states that theact v; performing the independent verificatio14 must be completelyseparate and independent of the initial alignment, installation, orverification.

Contrary to the above, on July 26, 1990, Steps 5.13.1 and 5.13.2 ofPlant Procedure 1 PSP 03 AF 0001 Revision 6, " Auxiliary TeedwaterPump 11 Inservice Test," were performed concurrently and were,therefore, not completely separate and independent. This resultedin a failure to detect that Test Line Isolation Valve AF0040 waserroneously aligned in a locked open position. This error was '

discovered following a reactor trip on August 6, 1970, whenauxiliary feedwater from Auxiliary Feedwater Pump No.11 wascirculated back to the auxiliary feedwater storage tank through the t

locked open valve instead 9f adding water to steam Generator A asdesigned.

This is a Severity Level IV violation. (Supplement I) (498/9028 01),

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A1/015.N10

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AttachsentST.HL. AE. 3596Page 2 of 3

2. Failure to Prqvide Adecuate Acceptance Criteria

10 CFR Part 50, Appendix B, Criterion V requires, in rett, that !

procedures include appropriate acceptance criteria for determining-

that important activities have been satisfactorily accomplished, i

South Texas Project Technical Specifications, paragraph 6.8.1.a.requires that procedures for activities identified in Appendix A ofRegulatory cuide 1.33, Revision 2, February 1978, be established,implemented, and maintained. Paragraph 3 to Regulatory Guide 1.33

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requires that instructions for energizing, filling, venting,draining, startup, shutdown, and changing modr.s of operation beprepared for the chemical and volume control system (includingletdovn/ purification system).

Cor.trary to the above, on August 6. 1990, neither OperationsProcedure 1 POP 02.CV.0004, ' Chemical Voluue sad Control SystemSubsystem,' Revision 8, or any administrativi procedure containedadequate acceptance criteria for determining hat the activities toplace a mixed bed desineraliser in service had been satisfactorilyaccomplished.

This is a Severity Level IV violation. (Supplement 1) (498/9028 02)

II. Houston Limhting & Power Position:

1. HL&P concurs that this violation occurred and attaches LER 90 006 inresponse to this violation.

2. HL&P concurs that this violation occurred.

I III. Reason for Violationl

,

1. See attached LF.R 90 006.

2. The cause of this event was the procedure for placing the,

desineraliser in service did not requite a sample or provide an'

acceptance criteria for boron concentration prior to demineralizeruse. Additionally, the procedure for borating the desineralizer wasalso less than adequate,

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A1/01$.N10

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'tAttachment

' ST.HL.AE 3596Page 3 of 3 |

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IV. Corrective Act!P.nt!,

1. See attached 12R 90 006, corrective actions 4 8.,

2a. The procedure for placing domineralizers ir service has been revisedto require domineralizer sampling and to specify acceptance criteriawhen placing a demineralizer in service, j

b. The procedure for borating domineralizers has been changed to ,

require the domineralizer outlet isolation valve to be closed forthe demineralizer that is not being flushed for sampling. This will ;

assure that only one demineralizer is flushed and sampled at a time.The procedure has also been revised to ensure a representative >

sample is obtained from the demineralizer being borated.- +

V. Date of Tull Como11ance:

H14P is in full compliance at this time.

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The Light.

c o m p a n y soutunn Projn: unuie Cennetleig station,

P. O. Bn FH Wadi.onh.Tu n 77o3Houston LI htin & Power

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August 31,1995ST.HL.AE.3547

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l File No.: C26 s

10CFR$0.73

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20$$$

South Texas Project Electric Cenerating StationUnit 1 ,

Docket No. STN $0 498 -'

Licensee Event Report 90 006 Regardinga Manual Reactor Trip Due to Full closure of a

Teedveter Isolation Valve Durine Partial Stroke Testine

Pursuant to 10CTR$0.73, Houston Lighting & Power Company (HIAP) submitsthe attached Licensee Event Report (1.ER 90 006) regarding a manual reactortrip due to full closure of a feedvater isolation valve during partial stroketesting. This event did not have any adverse impact on the health' and safety *

,"

of the public.

If you should have any questions on this matter, please contactMr. S. M. Head at (512) 972 7136 or myself at (512) 972 7921.

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Warren H. Kinsey,Vice PresidentNoclear Generation

SMH/aap

Attachment: LER 90 006 (South Texas / Unit'1)

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^1 M * 1*L01 A Subsidiary of Houston industries incornotated

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Houston 1.lghtin & Power Cdtnpany | ST.HL.AE+3$47' N'': C26South Teiss Project Electric (4nerating Station ,

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cc:

Regional Administrator, Region IV Rufus S. ScottNuclear Regulatory Commission Associate General Counsel ,

611 Ryan Plaza Drive Suite 1000 Houston Lighting & Power CompanyArlington, TX 76011 P. O. Box 61867

Houston, TX 77208Coorge Dick, Project ManagerU.S. Nuclear Regulatory Commission INPO

Washington, DC 20555 Records Center1100 circle 75 Parkway

J. 1. Tapia Atlanta, CA 30339 3064'

Senior Resident Inspectorc/o U. S. Nuclear Regulatory Dr. Joseph M. Hendriecommission 50 Be11 port Lane

P. O. Box 910 Be11 port, NY 11713Bay City. TX 77414

D. K. LackerJ. R. Novman, Esquire Bureau of Radiation ControlNewcan & Holtzinger, P.C. Texas Department of Health1615 L Street, N.W. 1100 West 49th StreetWashington, DC 20036 Austin, TX 78704

D. E. Ward /R. P. VerretCentral Power & Light CompanyP. O. Box 2121Corpus Christi, TX 78403

J. C. lanterDirector of GenerationCity of Austin Electric Utility721 Barton Springs RoadAustin, TX 78704 ,

R. J. Costello/M. T. HardtCity Public Service Board *

P. O. Box 1771San Antonio, TX 78296 ,

,

lRevised 12/15/89

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| L4/NRC/

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LICENSEE EVENT REPORT (LER) 88 " '8 8 *i *|

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South Texas, Unit 1 o is |o go |c|4|9 8 i[or| 0 61

'"''"' Manual Reactor Trip Dae to Full Closure og aFeedwater Isolation Valve During partial Stroke Testint

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i On July 30.1990, Unit 1 was in Mode 1 at 1004 power. At approximately 1946,Feedwater Isolation Valve 1A fully closed during a partial stroke surveillancetest. The resultant loss of feedwater flow caused a decrease in steamgenerator level and the reactor was manually tripped. The unit was stabilizedwith the exception of level in Steam Cencrator 1A which did not recover. due toa mispositioned recirculation test valve in the Train A Auxiliary FeedwaterSystem (AFV). The recirculation test valve us returned to the requiredposition and Steam Cenerator 1A level was recovered. The Teedvater Isolation

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Valve closure was caused by a technician inadvettently contacting the wrong'

terminal with a test jumper. The cause of the miepositioned recirculationtest valve could not be conclusively established; hswever it is likely thatthe valve was not correctly repositioned during a sur >eillance test prior tothe event, and this error was nct discovered due to a lack of adequateindependent verification. Corrective actions include: issuance of training

bulletins concerning use of junpers; evaluation of alternative designs toobviate the need to perform the partial stroke test with jumpcies; and.issuance of a memorandum to operations personnel to reenforce the requirementspertaining to independent verification.

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|UCENSEE EVENT REPORT (LER) TEXT CONTINUATION |maono o e =o me+o. |i **"j nie,ais eva

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DESCRIPTION OF EVENT:

on July 50,1990, Unit 1 was in Mode 1 at 1006 power. At 1946, Feedwateri Isolation Valve (WIV) 1A fully closed during performance of a partial stroke,

surveillance test. Steam Cenerator (SC) 1A level began decreasing and the ,

reactor was manually tripped since an automatic reactor trip was imminent dueto low steam generator water level. The turbine tripped, Feedwater Isolationoccurred on low Reactor Coolant System average temperature, and AuxiliaryFeodwater (AW) flow initiated on low. low steam generator level as expected.No other Engineered Safety Feature actuations occurred during this event.

' Emergency Operating Procedures were entered and the plant was stabilized with,

the exception that level did not recover in Steam Generatcr 1A as expected.Operations personnel determined that a recirculation valve on the 'A' train of

AW was nispositioned causing the flow to return to the Auxiliary FeedwaterStorage Tank (AWST). The recirculation valve was repositioned to recover SC1A level. The NRC was notified of this event at 2135 hours.

The WIV's are hydraulically operated with a nitrogen charge in the uppercylinder. The valve is closed by opening one or both of two solenoid valvesin parallel which dumps hydraulic fluid back to a reservoir; this allows thenitrogen charge to drive the valve closed. The partial stroke test verifiesthat both solenoids open and the WIV closes to the 906 position. Solenoidpositio. is sensed by reed switches connected to the test circuitry. The

i solenoids and reed switches are located within the valve yoke and aredifficult to maintain at power. If a reed si' itch is not functioning

cort ectly, as is the case with WIV 1A, an 'a.' ternate * partial stroke testprot edure using jumpers is employed which allovs testing each solenoidindividually.

The 'siternate" partial stroke test procedure specit'?es use of alligator clipsto connect jumpers. Prior to the event, a technician had installed thejumpets in a relay cabinet as specified in the test procedure. However, priorto actaally conducting the stroke test, the alligator clip of a landed jumperslipped off and Cell to the floor. In the process of relanding the jumper,contact was inadvertently made with an adjacent terminal, causing WIV 1A toclose.

During the post. trip recovery process, Operations personnel observed thatSteam Generator 1A level continued to decrease even though the associated AWflow was approximately 600 gpa. The 'A' train AW pump was secured af terreceiving a low discharge pressure alars. Cross connect valves were opened inan attempt to feed Steam Cenerator 1A from a different AW train; however,this proved unsuccessful. Subsequently, the "A* train recirculating testvalve was discovered to be locked open instead of being in the required' locked closed' position. This condition diverted AW flow back to the AWST,thereby preventing AW flow from entering Steam Generator 1A. Therecirculation test valve was repositioned and AW flow was established toSteam Generator 1A.

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An invest 15ation determined that the last known time the recirculation valve(

was manipulated was on July 26 during a monthly AW inservice pump test.There is no record of any other activities that would have caused the valve to ,

be operated between July 26 and the date of the event. There is also noi

evidence of maliciousness or tampering. However, it was determined that aless than adequate independent verification was performed on the part of the !

two operators assigned to manipulate the valve during the July 26 test.Independent verification is the act of checking a condition, such as valveposition, separately from establishing the condition or component position.Contrary to this philosophy, it was determined that both operators werepresent at the valve at the time it was to be closed, thus violating theintent of independent verification. It has been concluded, therefore, thatthe valve was apparently not correctly positioned by one operator (possibly '

,

due to the orientation of the valve), and that this condition was notdiscovered by the second operator due to a lack of adequate independent,

verification.

CAUSE OF EVENT:

The direct cause of the manu31 reactor trip was a failed closed feedwaterisolation valve. The failed. closed feedwater isolation valve was caused by atechnician inadvertently contacting the wrong terminal with a test jumper. A

f contributing factor was that the test procedure specified use of alligatorclips, which are prone to fall off the tensinals used during the test.Additional contributing factors are that the WIV's solenoid valve reedswitches were not functioning, and the design is such that they are difficultto maintain at power. With the reed switches not functioning, a successfulpartial stroke test could not be performed without the use of jumpers.

The cause of the mispositioned AW recirculation valve could not beconclusively established; however, it is likely that the valve was notcorrectly positioned by one operator'and that this error was not discovereddue to a lack of adequate independent verification on the part of a secondoperator.

ANALYSIS OF EVENT:

Reactor Protection System and Engineered Safety Features actuations arereportable pursuant to 10Cnt50.73.(a)(2)(iv). All safety systems responded asexpected, with the exception of Auxiliary Feedwater System Train A. Steam

Cenerator 1A level decreased significantly and remained low for approximatelyone hour because AW flow was diverted back to the AWST due to a locked.openrecirculation test valve. A minimum wide range level of 31% was achieved atapproximately 50 minutes after the trip. An adequate heat sink was maintainedduring the event by maintaining AW flow to "B", 'C', and 'D' steam

geneav ors.

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I _ south Texas. Unit 1 0|6|c|6|0|4|9|8 9| ( 0| Q 6 -Q 0 01 4 M 0| 6- -

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! Technical Specification 3.7.1.2 requires at least four independent steam| getierator auxiliary feedwater pumps and associated flow paths to be operable

in Modes 1, 2, and 3 including three motor. driven and one turbine driven ;

pumps. Under the worst case Design Basis Accident scenarios, including singlei failure, one train of A W is adequate to cool the RCS even if the 'A' train of

.

|| AW is out of service. In recognition of this fact, the Technical >

I Specification allows an unlimited outage time for the 'A' train of AN withthe stipulation that action be immediately initiated to return the 'A' train'

to service. Upon discovering the cause of the inoperability of 'A' train,

action was immediately taken to return the train to service. Since the DesignBasis Accident can be adequately mitigated with the 'A' AW trainout of service, this particular event had mi0imal safety consequences.

If the mispositioned valve had occurred on one of the other A W trains, the;

worst case scenario is a main ateam line break ar a feedwater line break thatis assumed to remove the cooling capacity of the AW train on the affectedsteam generator. For these events the following cases were analyzed:

Train B Valve Mispositioned: For this sconario, the worst case

situation would arise if the break were located in the 'C' train. TheAW design is such that if the single failure is assumed to be in the'A' actuation train of the Solid State Protection System, then neitherthe 'A' or 'D' trains of A W would be automatically actuated. However,one of the early steps in performance of the F.mergency OperationProceduros is verification of AW actuation. AW flow would be manuallyinitiated by control room personnel, thus providing cooling flow to thesteam generators.

Train C Valve Mispositioned: This scenario is similar to the 'B' train

scenario described above.

Train D Valve Hispositioned: For this case, the 'D' train is, .

unavailable due to the valve being mispositioned. In addition, one

train of AW is assumed unavailable due to the break and one train ofAW is unavailable due to a single failure, i.e., a standby dieselgenerator failed to start under loss of alternating current. This wouldstill leave one train of AW available to provide cooling to the RCS.

Since it is possible to readily provide flow to at least one steam generatorwith a locked open recirculation valve on any AW train, the safetyconsequences of a locked open valve on any one AW train are minimal.

The above cases have been analyzed in the Auxiliary Feedwater SystemReliability Evaluation provided in Appendix 10A of the Updated Final Safety I

IAnalysis Report. Specifically, this reliability study included the assumptiont. hat a recirculation valve would be mispositioned with a frequency of 1 in 200manipulations. STP experience is consistent with this assumption.

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COPJtECTIVE ACTI@|

The following corrective actions are being taken as a result of this event:

A training bulletin will be issued by September 12, 1990 to 14,C:

1) Technicians which will discuss this event and reemphastae individualresponsibilities in regard to critical testing manipulations.

The partial stroke surveillance test procedures as well as other2) surveillance procedures that use jumpers will be reviewed to developenhancements that can minimize the potential for reactor trips orEngineered Safety Teatures actuations. This review will becompleted by December 7,1990.

An evaluation will be performed to determine if an alternative3)design can be developed which would allow for partial stroke testingof the IVIVs without the use of jumpers. This evaluation will be

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completed by January 31, 1991.

4) Valve lineups were performed immediately and independently verifiedon various valves in the major flow paths in the followingsafety.related systems for both Unit 1 and Unit 2: Auxiliary

j Teedwater, Containment Isolation, Main peedwater, Containment Spray,|

and Safety injection. Valve lineups were also performed onaccessible Engineered Safety Teature valves in the tecked ValveProgram and Standby Readiness 1.ineups were performed on the StandbyDiesel Generators on both Unit 1 and Unit 2. No deficiencies wereidentified during these lineup checks.

5) The operators involved in the ATV valve manipulation were counseled. as to the appropriate methods for performing independentverification.

6) A memorandum has been forwarded to the operating staff reemphasizingthe need to 'self verify * all sanipulations to ensure that thedesired result has in fact occurred.

7) A memorandum has been forwarded to the operating staff reemphasizingthe importance of and requirements for independent verification andthe proper methods of verifying valve positions.

8) This event will be included in operator continuing training, withemphasis placed on the ramifications of misaligning the AuxiliaryTeedwater System and the requirements for Independent Verification.This action will be completed by November 30, 1990,

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ADDITIONAL INftRMATION:

There has been a previously reported event (IDt 2 89 019) concerning a reactor i

; trip caused by a WIV failing closed; however, the event was not associated ,

with a test jumper but was caused by a failure in the test circuitry..

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