IR 05000498/1987003
| ML20215K028 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/16/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8706250193 | |
| Download: ML20215K028 (2) | |
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JUN.16 1987 '
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In Reply Refer To:'
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Dockets:. 50-498/87-03
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50-499/87-03 l
Houston Lighting & Power Company i
ATTN:
J. H. Goldberg, Group Vice
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President, Nuclear l
P. O. Box 1700 l
Houston, Texas 77001 j
Gentlemen:
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Thank you for your letter of June 5,1987, in response to'our letter and
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Notice of Violation dated May 15, 1987.. We have reviewed your reply and find
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it responsive to the concerns raised in our Notice of Violation. We will J
i review the implementation of your corrective actions during a future inspection
'to determine that full compliance has been achieved and will be maintained.
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Sincerely,
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wonai stened 61 m t. n A u.~
J. E. Gagliardo, Chief-Reactor Projects Branch cc:
i Houston Lighting & Power Company ATTN:
M. Wisenberg, Manager, Nuclear Licensing P. 0. Box 1700
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' Houston, Texas ~ 77001 l;
Houston Lighting & Power Company
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ATTN: Gerald E. Vaughn, Vice President l
i Nuclear Operations P. O. Box 1700'
Houston, Texas 77001 i-Texas Radiation Control Program Director
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June 5, 1987 ST-HL-AE-2173 I
File No.: G2.4 l
$ $ $ bk. b U. S. Nuclear Regulatory Commission
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JUN I 21987
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Attention:
Document Control Desk p
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Washington, DC 20555
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South Texas Project
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Units 1 and 2
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Docket Nos. STN 50-498, STN 50-499-Response to Notice of Violation 8703-01 Houston Lighting & Power Company has reviewed Notice of Violation 8703-01 dated May 15, 1987 and submits the attached response pursuant to 10CTR2.201.
If you should have any questions on this matter, please contact Mr.
S. M. Head at (512) 972-8392.
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G. E. Vaughn Vice President Nuclear Plant Operations SMH/hg Attachment:
Response to Notice of violation 8703-01
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ST-HL-AE-2173
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. File No.: C2.4 Houston Lighting se Power Company
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Regional Administrator, Region IV M.B. Lee /J.E. Malaski
' Nuclear Regulatory Commission City of Austin-
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611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX. 76011 Austin, TX 78767-8814 N. Prasad Kadambi, Project M'anager A. von Rosenberg/M.T. Hardt U.S. Nuclear Regulatory Commission City'Public Service Board 7920' Norfolk' Avenue P.O. Box 1771 Bethesda, MD 20814 San Antonio, TX 78296
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Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards
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U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 H Street Bethesda, MD 20814 Washington, DC.20555 Dan R. Carpenter
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Senior Resident Inspector / Operations c/o U.S. Nuclear Regulatory Commission P.O. Box 910
Bay City, TX 77414 Claude E. Johnson i
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Senior Resident Inspector / Construction c/o U.S. Nuclear Regulatory Commission P.O. Box 910 Bay City,'TX 77414 i
l M.D. Schwarz, Jr., Esquire J
Baker & Botts-i One Shell Plaza
.j Houston, TX. 77002
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J J R. Newman, Esquire Newman & Holtzinger, P.C.
1615 L Street,.N.W.
Washington, DC 20036
T.V. Shockley/R.L. Range Central Power & Light Company P. O. Box 2121-Corpus Christi, TX 78403 L
L4/NRC/rv/hg 0 Revised 2/3/87 i
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Attachment ST-HL-AE-2173
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File No.: G2.4 Page 1 of 2
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South Texas Project Units 1 and 2
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Docket Nos. STN 50-498, SIN 50-499
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Response to Notice of Violation 8703-01
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I. Statement of Violation Criterion V of Appendix B ~ to 10CFR50, requires that activities - affecting-quality be prescribed by documented instructions or procedures,.and shall be accomplished in accordance with these procedures. The South Texas Project Operations Quality Assurance Plan 11mplements this requirement.
Plant General Procedure'(PCP) OPCP03-ZL-0002, Revision'4', "New Fuel Receipt, Inspection and Storage," Step 8.4, requires.that inspection personnel 1 perform.a contamination survey of the~ fuel assemblies to determine if the alpha contamination is within the procedure limit of less than 20 dpm..This reading must also be properly recorded in the
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Contrary to the above, on February 18,'1987, the NRC inspector noted the alpha contamination' readings for two fuel assemblies were inaccurately recorded as less than 50 dpm.
This-inaccurate recording exceeds the procedure. limit l and requires that precautionary measures be undertaken.
No actions were taken by the' licensee based on this recorded data. It was determined later that the actual contamination readings were well-
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below the 20 dpm requirement.
II. Reason for Violation
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This violation resulted from failure to follow procedures. However, the
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procedures involved were written in a manner that increased the possibility of human error in following procedural requirements.
Specifically, the procedures which required alpha contamination readings for both the fuel and shipping cask indicated different acceptable levels for each. -The acceptable limit for the exterior of the shipping cask was 50 dpm while the corresponding limit for the fuel was 20 dpm..In the case sited in this violation, the technicians involved in monitoring the fuel simply recorded that the levels were less than the higher of the two acceptance limits (i.e. < 50 dpm ) rather than below the lower limit of detection.
In all cases, the intent was to record the fact that no detectable-level of contamination existed on the fuel. No precautionary measures were undertaken by personnel because it was recognized that the j
recorded contamination level meant that no detectable contamination existed.
j III. Corrective Action Taken and Results Achieved All data sheets for fuel receipt were reviewed and corrected as necessary. Verification in each case was obtained that in fact no detectable level of contamination on the fuel elements existed.
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Attachment ST-HL-AE-2173
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File No.: G2.4
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IV. Corrective Steps Taken to Prevent Recurrence To avoid recurrence"of this violation, STP has taken the following actions:
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'o Health & Safety technicians involved with fuel receipt attended
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training to emphasize procedural requirements related to this violation.
Procedural revisions have.been made to provide the contamination o
limits on the data sheets, The limits for alpha contamination have been revised so that limits o
for both fuel and the shipping cask surface are the same.
V. Date of Full Compliance
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STP is in full compliance at.this time. The first core load has been received on site. No further violations of this type have occurred.
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