IR 05000498/1987026

Ack Receipt of Informing NRC of Steps Taken to Correct Deviation Noted in Insp Rept 50-498/87-26.Deviation 50-498/87-26-10 Retracted Based on Addl Info Provided & Verification by Senior Resident Inspector

ML20234B043
Person / Time
Site:	South Texas
Issue date:	09/14/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8709180243
Download: ML20234B043 (2)

Text

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.,- 5 SEP 141987 In Reply Refer To:

Dockets: 50-498/87-26 50-499/87-26 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President, Nuclear P. O. Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of July 27, 1987, in response to our letter and Notice of Deviation dated June 25, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Deviation. Also, we are retracting Deviation 498/8726-10 based on the additional information you provided and verification of this information by our Senior Resident Inspector. This deviation concerned performance testing following plant modifications. We will review the implementation of your corrective actions for the other deviations during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Orlejnal S1; mad Cy J. E. Gg.ra da J. E. Gagliardo, Chief Reactor Projects Branch cc:

Houston Lighting & Power Company ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Houston Lighting & Power Company ATTN: Gerald E. Vaughn, Vice President Nuclear Operations P. O. Box 1700 Houston, Texas 77001 Texas Radiation Control Program Director bec: (see next page)

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i bec distrib. by RIV: j RPB DRSP l RRI-OPS R. D. Martin, RA 5 RRI-CONS Section Chief (RPB/C) f RPSB MIS System RIV. File D. Weiss, RM/ALF RSTS Operator R. Pirfo, 0GC R. G. Taylor, RPB/C RSB Project Inspector, RPB R. Hall P. Kadambi, NRR Project Manager i

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m The Light l company Houston Lighting & Power

. O. Box 17% Houston, Texas 77%1 (71M 2284211 M @ M 0W S 1b JL 311987 o 1

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July 27,1987 ST-HL AE 2300 File No.: G CFR2.201

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Deviation 8726 i

Reference (1) NRC Inspection Report 87-26 dated 6/25/87 (ST- AE-HL 91310)

Houston Lighting & Power Company has reviewed Notices of Deviation 498/8726-04, 498/8726 06 and 498/8726-10 dated June 25, 1987 (Reference 1) and submits the attached response pursuant to 10CFR2.20 .

If you should have any questions on this matter, please contact M S. M. Head at (512) 972-839 y G. E. Vaughn Vice President Nuclear Plant Operations o

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Attachments: Response to Notices of Deviation .-

(1) 498/8726-04, (2) 498/8726-06, (3) 498/8726-10

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A Division of Houston Industries Incorporated l L4/NRC/rd g-0 E o\

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ST-HL AE-2300 Houmon Ughdng se Power Cxnnpany File No.:0 Page 2

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Regional Administrator, Region IV M.B. Lee /J.E. Malaski Nuclear Regulatory Commission City of Austin 611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX 76011 Austin, TX 78767-8814

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N. Prasad Kadambi, Project Manager A. von Rosenberg/M.T. Hardt U.S. Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771 Bethesda, ED 20814 San Antonio, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 H Street Bethesda,.}UL 20814 Washington, DC 20555

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- Dan R. Carpenter Senior Resident Inspector / Operations c/o U.S. Nuclear Regulatory Commission P.O. Box 910 Bay City, TX 77414- j Claude E. Johnson Senior Resident Inspector / Construction c/o U.S. Nuclear Regulatory l Commission i P.O. Box 910 Bay City, TX 77414 M.D. Schwarz, Jr., Esquire ]

. Baker & Botts j

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One Shell Plaza Houston, TX 77002  !

l J.R. Newman, Esquire i Newman & Holtzinger, L Street, Washington, DC 20036, R.L. Range /R.P. Verret' N Central Power & Light Company P.. O. Box 2121 1 Corpus Christi, TX 78403 J

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L4/NRC/rd/hg-0 Revised 6/23/87

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Attachasnt 1 ST-HL AE-2300

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Page 1 of 2 (

l South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Deviation (498/8726-04)

I.A. Statement of Deviation Failure to Establish a Record Index Prior to Record Receipt In Table 3.12-1 of the STF Final Safety Analysis Report (FSAR), HL&P States Conformance to Regulatory Guide (RG) 1.88, Revision 2. RG 1.88

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endorses ANSI N45.2.9-1974, which states, in part, in Paragraph 3.2.2,

"The quality assurance records shall be listed in an index . . . . The

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index should be established prior to receipt of the records . . . .

The STP Document Type List (DTL) is the index maintained by HL&P for STP record In deviation from the above, expected quality assurance records had not been listed on the DTL prior to receipt by the Operations Document Control Center (ODCC.). For example, water chemistry analysis records and radiation and contamination survey reports were not listed in the DT II.A. Reason for Deviation In addressing this Deviation it is important to note that HL&P has considered ODCC as an " interim storage facility" As such, we have defined receipt to mean receipt by our permanent storage facility, i.e, the Records Management (RMS) vault. It was our intent, therefore, to ensure that records were on the DTL prior to their receipt at the RMS vaul The record types cited in the Deviation would have been incorporated in the DTL prior to their transmittal to RM III.A. Corrective Action Taken and Results Achieved

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Documents in ODCC have been inventoried and placed on the Operations section of the DTL (revision 2)..N Currently, we are identifying and placing on the DTL records that will be generated by NPOD as well as records to be generated by Operations QA/QC, the Security Department, the Nuclear Safety Review Board, the Independent Safety Engineering Group and Nuclear Training Department. This effort should adequately ,

address record types that may be generated in accordance with current plant procedures. In addition, Interdepartmental Procedure (IP) 1.31Q requires department heads to provide input to the DTL for new or modified records as applicabl *

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IV.A. Corrective Steps Taken to Prevent Recurrence See above for all actions taken as a result of this concer L4/NRC/rd/hg 0 L _ _ _ _ _ ----_--- - - - - - - - - -

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Attachment 1

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ST-HL-AE-2300

. File No.: G Page 2 of 2 V.A. Date of Full Comoliance Records currently located in ODCC have been inventoried and the DTL has been updated appropriately. As indicated above, the indexing effort of other records is currently taking place and is expected to be complete by December 1, 198 .

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i Attachment 2 4 ST-HL AE-2300

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File No.: G Page 1 of 2 i

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I.B. Statement of Deviation (498/8726-06)

Inadequate Control of Records in a Temporary Working File ANSI N45.2.9 1974, states in Paragraph 4.3, "The designated authority shall be responsible for organizing and implementing a system of receipt l control of quality assurance record This system shall apply to the l receipt of records into a temporary working file and. the permanent '

storage file. As a minimum, a receipt control system shall include: ;

. A records check list designating the required quality assurance records, A record of quality assurance records received, and

) Procedures for receipt and inspection of incoming record I An adequate quality assurance record receipt control system had not I been established as illustrated by the following example o Daily Reactor Operator log sheets for the period February through April 1987 were filed loosely in non-fire rated ;

cabinet i o The Unit Supervisor, Reactor Operator, and Reactor Plant Operator (including Yard, Mechanical Electrical Auxiliary ;

Building (MEAB), and Turbine Generator Building (TGB)) Logbooks i (hardbound logs covering period from 1985 through 1986) were stacked without protection or control on top of the cabinets a holding the daily benchboard log sheet o The Unit Supervisor and Reactor Operator hardbound logbooks for I the periods before those mentioned above could not be located i in_ Nuclear Plant Operations Division (NPOD) or ODCC record !

storag o Seven record transmitt is for all Reactor Operations Division records have been executed and were available for audit. Most NPOD documents, required to be retained as quality records, are not forwarded to ODCC by transmittal, thus no accountability for record loc,ation exist ?

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Attachment 2 ST-HL-AE 2300

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G Page 2 of 2 II.B. Reason for Deviation The root cause for log sheets'being filed loosely in.non-fire rated cabinets, logbooks being stacked without protection or control.and logbooks that could not be easily located is the result of a failure to follow procedure Division management had not taken steps to ensure that division personnel were aware of storage requirements as defined in the Operation Quality Records Station-Procedur In regard to record accountability, the procedure governing receipt control of operations quality records permitted transmittal forms to be

. optional. As a result, in some cases forms were not use III.B. Corrective Action Taken and Results Achieved i As a result of the NRC's inspections a QA surveillance of NPOL was performed. .Similar as well as additional problems relative to quality records receipt were identified. Each division that maintains a quality record file has subsequently assigned a designated record custodian who is responsible for filing records, maintaining accountability, controlling access, indexing stored records and transmitting those records to the Record Retention Area. Appropriate action has been taken, including promulgation of a requirement to use transmittal forms,.to preclude problems in this area from recurrin Procedurally ODCC will not accept records without a transmittal for In addition, some divisions have subsequently determined that quality records will no longer be maintained outside of the ODCC and therefore-quality records will be transmitted to ODCC in an expeditious manne IV.B. Corrective Steps Taken to Prevent Recurrence See abov j V.B. Date of Full Compliance STP is in full compliance at this tim ,x

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Attechmant 3 ST-HL-AE-2300 File No.: G Page 1 of 2

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South Texas Project Units 1 and 2 Docket Nos. STN 50 498, STN 50-499 Response to Notice of Deviation (498/8726-10)

I.C. Statement of Deviation Failure to Conduct Performance Testing Following Plant Modifications In Table 3.12-1 of the STP FSAR, HL&P states confermance to RG 1.33,

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Revision 2. RG 1.33 endorses ANSI N18.7-1976, which states, in part, in Section 5.2.7, "A suitable level of confidence in structures, systems, or components on which maintenance or modifications have been i performed shall be attained by appropriate inspection and performance testin . ."

In deviation from the above, the licensee could supply no evidence that performance testing was being performed following installation or removal of temporary modification II.C. Reason for Deviation i HL&P programmatically, complies with ANSI N18.7-1976 via the. Maintenance Work Request (NWR) Program. Temporary modifications are installed and restored in accordance with the requirements of the MWR program. The '

requirements for post-installation testing and poet-restoration testing

_ are assessed per this program by the maintenance planner and the cognizant system enginee HL&P believes the inspector saw no evidence of post-installation or post restoration testing, because he apparently reviewed only Temporary Modification Request Forms and not the NWR Form Post-installation and post-restoration tests are described on the NWR forms. However, in the case of-the systems reviewed by the inspector, most of the Temporary Modifications (NPOD jurisdiction) were converted from Temporary Alterations (Startup's' jurisdiction) during system turnove Many of the Temporary Alterations had resulted from Startup's decision not to restore lifted leads after system pre operational test The pre-operational test procedures required that the non-restored leads be documented as Temporary Alterations. The leads were left non restored to preclude inadvertent Engineered Safety Features (ESF) actuation until ESF pre-operational testing was conducted, and no specific post-installation functional test was performed. The Startup program required only independent verification. Subsequent operation and ~

testing activities of these systems have served to functionally test the installation'of the alteration and it is believed that this did provide a " suitable level of confidence." Prior to performing ESF L4/NRC/rd/hg-0

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Attachment 3

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ST-HL AE 2300 ;

File No.: G Page 2 of 2

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pre-operational testing, MWRs were written to rostore the leads l initially lifted in the various system pre-operational test These MWRs stated that ESF pre-operational testing would serve as the post-restoration tes Therefore, HL&P is not in deviation of its commitment relative to ANSI N18.7-197 III.C. Corrective Action Taken and Results Achieved

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Based on the discussion above, corrective action is not necessar However, in preparation for entering the operational phase of Unit 1, we have enhanced the temporary modification program by revising the temporary modifications procedure to require that post installation and post restoration testin5 be specified on the Temporary Modification Request For Existing temporary modifications have been installed in accordance with this revisio IV.C. Corrective Steps Taken to Prevent Recurrence See above for all corrective action taken as a result of this issu V.C. Date of Full Compliance STP is presently in full complianc _

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