IR 05000498/1984016

Ack Receipt of Informing NRC of Steps Taken to Correct Deviations Noted in Insp Repts 50-498/84-16 & 50-499/84-16

ML20133J054
Person / Time
Site:	South Texas
Issue date:	07/29/1985
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8508090633
Download: ML20133J054 (2)

Text

- - _ - - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ __ ____ _ ___ _ ____

.

,N JUL 2 91985 In Reply Refer To:

Dockets: 50-498/ 84-16 50-499/ 84-16 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of April 25, 1985, in response to our letter and Notice of Deviation dated March 22, 1985. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Deviation. We will review the implementation of your ccrrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, orgnci nmq ni C.11 -

E. H. Johnson, Chief Reactor Project Branch cc:

Houston Lighting & Power Company ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Brian Berwick, Esquire Asst. Attorney General Environmental Protection Div.

P. O. Box 12548, Capitol Station Austin, Texas 78711 (cont,onnextpage)

RIV:RPB/C RPB NJ!

GLConstable/lk EHJohnson 1/7/85 7 1 / ;1/85 pt/

e500090633 ADOCK 0$0h 98 PDR PDR G

- _ _ _ . _-- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

i

.

.

Houston Lighting & Power Company -2-Lanny Alan Sinkin Citizens Concerned About Nuclear Power, Inc.

3022 Porter Street, N.W. #304

'

Washington, D.C. 20008 Charles Bechhoefer, Esquire l Chairman, Atomic Safety & Licensing l

!

Board U.S. Nuclear Regulatory Commission Washington, DC 20555 l

Dr. James C. Lamb, III

! 313 Woodhaven Road Chapel Hill, North Carolina 27514 i Frederick J. Shon Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Texas Radiation Control Program Director bec distrib. by RIV:

RPB R. P. Denise DRSP Resident Inspector-0PS R. D. Martin, RA Resident Inspector-CONST. RSTS Operator Section Chief, RPB/C RIV File D. Weiss,LFMB(AR-2015)

L.

--

.

.

.

.

.

The Light company

>__..____..._.__ .

n.,,,,,,,,, o xi,o,,, & i ,,,,.,. m n.,, ia,,, n.,,,,,,,,,. i . .,, ,,,,,,, a n, mm n April 25, 1985 ST-HL-AE-1238 File No.: G2.4,M22.3,Q17.1.1,P11.1 Mr. Robert D. Martin Regional Administrator, Region IV --

Nuclear Regulatory Commission r% [if (' j. ' []( '

611 Ryan Plaza Drive, Suite 1000 }

--- ' -

Arlington, TX 76001 APR 29 l985

Dear Sir:

"

- - ~ _ .l

.-

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Deviation 8416-01 Pursuant to the provisions of 10 CFR 2.201, attached is Houston Lighting &

Power Company's (HL&P's) response to the Notice of Deviation 50-498/8416-01, 50-499/8416-01 dated March 22, 1985. In response to a telephone request on April 22, 1985, Mr. Eric Johnson (NRC Region IV) verbally granted an extension in the time for submitting this response till April 26, 1985.

If you should have an Michael E. Powell at (713)y 993-1328.questions regarding this matter, please contact M Very truly yours,

.

q J. H. Goldberg y Group Vice President, Nuclear JHG/FAW/rka Attachment: Response to Notice of Violation (8416-01)

0Y h W2/NRC2/z S@ulg!!'? 5pp.

'

..

.

.  :

,

ST-HL-AE-1238 Ilouuon t.ighting & lber Cornpany File Number: G2.4,M22.3,Q17.1.1,Pil.1 Page 2 cc:

Hugh L. Thompson, Jr. , Director Brian E. Berwick, Esquire Division of Licensing Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Comission P. O. Box 12548 Capitol Station Washington, DC 20555 Austin, TX 78711 N. Prasad Kadambi, Project Manager Lanny A. Sinkin U.S. Nuclear Regulatory Commission 3022 Porter Street, N.W. #304 7920 Norfolk Avenue Washington, D.C. 20008 Bethesda, MD 20814 Oreste R. Pirfo. Esquire Claude E. Johnson Hearing Attorney Senior Resident Inspector /STP Office of the Executive Legal Director c/o U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Commission P. O. Box 910 Washington, DC 20555 Bay City. TX 77414 Charles Bechhoefer Esquire Dan Carpenter Chairman, Atomic Safety & Licensing Board Resident Inspector / South Texas Project U.S. Nuclear Regulatory Commission c/o U.S. Nuclear Regulatory Comission Washington, DC 20555 P. O. Box 2010 Bay City. TX 77414 Dr. James C. Lamb, 111 313 Woodhaven Road M. D. Schwarz, Jr., Esquire Chapel Hill, NC 27514 Baker & Botts One Shell Plaza Judge Ernest E. Hill Houston, TX 77002 Hill Associates 210 Montego Drive J. R. Newman, Esquire Danville, CA 94526 Newman & Holtzinger, P.C.

1615 L Street N.W. Mr. Ray Goldstein, Esquire Washington, DC 20036 1001 Vaughn Building 807 Brazos Director Office of Inspection Austin, TX 78701 and Enforcement U.S. Nuclear Regulatory Commission Citizens for Equitable Utilities, Inc.

Washington, DC 20555 c/o Ms. Peggy Buchorn Route 1, Box 1684 E. R. Brooks /R. L. Range Brazoria, TX 77422 Central Power & Light Company _

P. O. Box 2121 Docketing & Service Section Corpus Christi, TX 78403 Office of the Secretary U.S. Nuclear Regulatory Commission H. L. Peterson/G. Pokorny Washington, DC 20555 City of Austin P. O. Box 1088 Austin, TX 78767 J. B. Poston/A, vonRosenberg City Public Service Board P. O. Box 1771 San Antonio, TX 78296 W2/NRC2/z Revised 3/4/85 I

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

..

,

'

.'

'

Attachment ST-HL-AE-1238 File No.: G2.4 Page 1 of 3 South Texas Project Response to Notice of Deviation 50-498/8416-01 50-499/8416-01

!. Statement of Deviation Based on the results of an NRC inspection conducted during the period of November 1-December 31, 1984, and in accordance with NRC Enforcement Policy (10 CFR Part 2. Appendix C), 49 FR 8583, dated March 8, 1984, the following deviation was identified with Amendment 39 of the FSAR, dated June 27, 1984.

1. Section 9.2.2.2.1, page 9.2-12 states that there should be venting of trapped gases in the CCW surge tank, Contrary to the above, the trapped gases must be vented from the surge tank through the surge tank relief valve.

2. Section 9.2.2.3.2, page 9.2-15 states that should a large high radiation inleakage into the CCW system develop, the level in the surge tank will rise, and the high-high-level condition will be annunciated and the atmospheric vent on the tank closed.

Contrary to the above, no atmospheric vent is provided on the surge tank.

3. Section 9.2.2.3.2, page 9.2-15 states that if the surge tank pressure increases to the valve set pressure, the relief valve on the CCW surge tank will lift and discharge to the floor drain tank.

Contrary to the above, the discharge will be to the CCW sump.

4. Section 9.2.2.3.2, page 9.2-15 states that inside containment the relief valves discharge to the containment normal sump.

Contrary to the above, they discharge back to the CCW system downstream of the component isolation valve.

5. Table 9.2.2.1 states that the chemical addition tank has a volume of 250 gallons.

Contrary to the above, it appears that the tank capacity is 50 gallons.

6. Table 9.2.2.3 on " Failure Modes and Effects Analysis" states in the RHR heat exchanger section, that the atmospheric vent on surge tank will close to prevent releases of radioactivity.

Contrary to the above, no atmospheric vent is provided on the tank.

W2/NRC2/z

_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ __ _ _ _ _ _ _ .

"

..

'

.

• '

Attachment ST-HL-AE-1238 File No.: G2.4 Page 2 of 3 i

7. Section 11.5.2.9.12 states that "Upon initiation of a high or rate of change alarm, the monitor initiates closure of the component cooling water surge tank vent valve, FV-4500.

Contrary to the above, no vent valve is provided on the surge tank.

!!. Reply This item was identified by Mr. D. R. Carpenter (USNRC) during the inspection period of November 1-December 31, 1984.  !

The present text in FSAR Section 9.2.2 (Amendment 39) reflects the original chromate inhibitor design of the Component Cooling Water (CCW) system.

Replacement of this design with All-Volatile Treatment (AVT) has been under review since mid-1983. The design change to AVT in the CCW system was identified on the PalD and placed on " HOLD" in July 1983. The "h0LD" was subsequently removed with the completion of the project review and approval i

on June 5, 1984 (Rev.2, DCN 5). At this time, the responsible engineer

! should have commenced a FSAR text revision, by initiating a Safety Analysis i Report Change Request (SARCR). In November, the NRC inspectors identified i several inconsistencies between the FSAR text and the issued PalD's and

.

brought them to the attention of HL&P (1/2/85). Upon notice from HL&P, I Bechtel, (DEC) began a review of the FSAR text and the current revision of l the PalD to resolve the inconsistencies.

!

l This deviation occurred due to failure to follow established project procedures.

I In this particular incident, the change resulted from removing a " HOLD" on the PalD. Upon issuance of the revised Pa!D, the responsible engineer should l

have initiated the SARCR to conform the FSAR to the design change.

In early 1984 a Licensing Commitment Tracking System action item was assigned which specifically requires the affected FSAR section (9.2.2) to be reviewed relative to the AVT design change. However, this activity was not scheduled to take place until March 1985.

l III. Corrective Steps Taken or To Be Taken The deviations between the FSAR Section 9.2.2 and the current design as depicted on the PalD will be corrected by an amendment to the FSAR. BEC SARCR 522 was initiated to correct the FSAR on January 24, 1985. The deviation involving the Failure Modes and Effects Analysis (FMEA) Table has been resolved, and an updated CCW FMEA was initiated under DEC SARCR 495 on November 5, 1984. The FSAR will be amended to correct the identified inconsistencies in a forthcoming amendment.

W2/NRC2/z

I.,*

.

• .

a' Attachment ST-HL-AE-1238 File No.: G2.4 t Page 3 of 3 IV. Corrective Action Which Will Be Taken to Avoid Further Deviations The following Bechtel Engineering Department Procedures (EDP) provide the means for identification and control of initiating SARCR's that are required based on design changes:

EDP 4.72 Configuration Control Procedures EDP 4.73 Design Change Approval Request EDP 4.46 Project Drawings l

EDP 4.1 Design Criteria EDP 4.23 Control of FSAR Change Requests l

i As a supplement to these procedures, other programs are in place to assure i the consistency of the FSAR with the design. These programs include the Engineering Desi Review Program (gn Verification GPR2.25). Program These ongoing (EDPprovide programs 4.27)additional and the Independent Des assurance that any inconsistancies between the project design and the FSAR are identified and corrected in a timely manner.

Training will be performed to further emphasize the procedural requirement to update project licensing documents upon approval of design changes. Emphasis will be given to situations where a release of a hold could effect the FSAR.

This training will be completed by May 24, 1985.

In addition, a review of a representative sample of those FSAR sections describing systems where design changes were reflected by " HOLD"s on P&lD's will be completed by May 31, 1985. This review will assure that the design status is correctly reflected in the FSAR.

V. Date When Full Compliance Will Be Achieved HL&P is now in full compliance. It is HL&P's tosition that the FSAR and project design disclosure documents are in conformance when the need to change the FSAR is formally identified by issuance of a HL&P FSAR Change Notice. The Bechtel SARCR's 522 and 495 were issued as HL8P FSAR Change Notices 483 and 474 on April 23, 1985 and April 16, 1985 respectively.

,

W2/NRC2/z

<