ML20029B022
| ML20029B022 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/21/1991 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hall D HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9103050255 | |
| Download: ML20029B022 (3) | |
See also: IR 05000498/1990036
Text
76 U
FEB 21 1991
Docket Nos. 50-498/90-36
50-499/90-36
License Nos. NPF-76
NPF-80
Houston Lighting & Power Company
ATTN:
Donald P. Hall, Group
Vice President, Nuclear
P.O. Box 1700
Houston, Texas 77251
Gentlemen:
Thank you for your letter of January 17, 1991, in response to our letter
and Notice of Deviation dated December 17, 1990. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Deviation. We
will review the implenentation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
Origir) S%ned By:
Samuct J. Collins
Samuel J. Collins, Director
Division of Reactor Projects
cc:
Houston Lighting & Power Company
ATTN: Manager, Operations Support
Licensing
P.O. Box 289
Wadsworth, Texas 77483
City of Austin
Liectric Utility Departnant
ATTN:
J. C. Lanier/M. 8. Lee
P.O. Box 1088
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Houston Lighting & Power Comp 6ny
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City Public. Service Board
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ATTN:
R. J. Costello/M. T.- Hardt
P.O. Box 1771
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San Antonio, Texas 78296
Neiman & Holtzinger,.P. C.
ATTN: Jack R. Newman, Esq.
1615 L Street NW
Washington, D.C.
20036
Central Pwer and Light Company
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ATTN:
R. P. Verret/D..E. Ward
P.O. Fox 2121-
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Corpus Christi, Texas 78403
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INFO
Records Center
1100 Circle 75 Parkway
Atlanta .- Georgia- 30339-3064
Mr' Joseph M. Hendrie =
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50 Be11 port Lane.
Be11 port New York 11713
Bureau of Radiation Control
State of Texas
1101 West 49th-Street
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Judge,:Matagorda County
hatagorda County Courthouse
1700 Seventh Street
Bay City, Texas = 77414
Licensing Representative
Houston Lighting & Power Company
Suite 510
Three Metro Center
Bethesda, Maryland 20814
Houston Lighting & Power Company
ATTN:- Rufus S.-Scott, Associate
General Counsel
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P.O.l Box 61867
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Houston, Texas 7720fa
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Houston Lighting & Power Conpany
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R. D. Martin
Resident Inspector
Section Chief (DRP/0)
MIS System
DRSS-RPEPS
Lisa Shea, RM/ALF
Rly file
R. Bachmann 0GC
RSTS Operator
Project Er gineer (DRP/D)
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The Light
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PO Bos r,00 llouston. It xn 77001
(715) n'6 9.11
llouston 1)ghting k Power
January 17, 1991
ST llL AE 3607
1 '* No.:
G3.12
.
1DCIRt 201
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U. S. Nuclear Regulatory Conatission
Attention:
Doeweent Control Desk
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Vashington, DC
20555
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3 2 U l99I
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South Texas Project Electric Cenerating Statit>h '
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Units 1 and 2
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Docket Nos. STN 50 498, STN 50 499
Er.Eponr.e tp Not i ee .p.L.Dt.ylplitIL202!c 0.1
Refersnee (1) NRC Inspection Report 90-36 dated D(cen2ber 17, 1990
(ST-AE llL 92631)
llouston Lighting 6 Power Cortpany has reviewed Notice of Deviation
9036 01 dated Deccaber 17, 1990 (Re f erence 1) and s.ubrnit s the at t achc d
response pursuant to 10CFR2.201.
If ynu should have any questions on this rtatter, please contact Mr.
S.
D. Phillips at (532) 972 8472 or tryself at ($12) 972 7298.
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}g A. V. flar ri son
Manager,
Nuclear Licensing
SDP/sgs
At tachn ent :
Response to Notice of Deviation
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ST.HL AE.3667
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flouston lighting k Powcr Contany
File No.:03.12
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South Tem Project 1.lectric Generating Station
78 e2
cc:
Regionni Administrator, Region 1v
Rufus S. Scott
Nuclear Regulatory Comnission
Associate General Counsel
611 Ryan Plaza Drive, Suite 1000
Houston Lighting & Power Cottpany
Arlington, TX 76011
P. O. Box 01867
Houston, TX 77208
George Dick, Project Manager
U.S. Nuclear Regulatory Cotraission
Vashington, DC 20$$5
Records Center
1100 circle 75 Parkway
J. 1. Tapia
Atlanta, CA 30339 3064
Oenior Resident Inspector
c./o U. S. Nuclear Regulatory
Dr. Joseph M. Hendrie
Consission
50 Be11 port Lane
P. O. Box 910
Be11 port, !?Y 11713
19y City TX 77414
D. K. Lacker
J. R. Newman, Esquire
Bureau of Radiation Control
Nevitan 6 Holtzinger, P.C.
Texas Depart: tent of Henith
161$ L Street, N.V.
1100 Vest 49th Street
Washington, DC 20036
Austin, TX 78756 3189
R. P. Verret/D. E. Ward
Central Power 6 Light Cortpany
P. O. Box 2121
Corpus Christi, TX 76403
J . C . Lant e r/M . B . Le e
City of Aus tin
Electric Utility Department
P.O. Box 1088
Austin, TX 78767
R. J . Costello/M. T. Hardt
City Public Service Board
P. O. Box 1771
San Antonio, TX 78296
Revised 10/08/90
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Attachment
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ST HL AE 3667
Page 1 of 2
South Texas Project Electric Cenerating Station
Units 1 and 2
Docket Nos. STN 50 498, STN 50 499
Response to Notice of Deviation 9036 01
1.A
$1a t etten t of DeviatiSD
During an KRC inspection conducted November 5 9, 1990, a deviation
of yotr Safety Evaluation Report (SER) was identified.
In
accordance with the ' General Statement of Policy and Procedure for
NRC Enforcement Action," 10 CFR Part 2, Appendix C (1990), the
deviation is listed below:
of the STF n dated Final Analysis Report
Section 13.1.2.2.1
r
(UFSAR) states 'The administ n,9 ve aide is responsible for
tasks of an adainistrative nature which are required during the
shift. The aide performs routine administrative duties rnd
processes such as routing records, logs and corresponder.ce for
the control room operations staff as required. The aide
reports to the shif t supervisor."
Section 13.5.1.1 of the STP SER (NUREC 0781) states, in part,
'Each shift vill have administrative aides to relieve the shift
supervisor of routine administrative duties and to process end
route various records, logs and correspondence."
Contrary to the above, the November 1990 Administrative Aide
Shift Scheduling Report for Unit 2, which was signed by the
Unit 2 Operations Manager on October 25, 1990, and implemented
November 1,1990, did not provide an administrative aide on the
first Saturday shift or for any of the Sunday shifts during the
month.
II.A.
Response to the Deviation
To comply with THI Action I. A.1...,
"Shif t Supervisor
Responsibilities-Delegate Non-Safety Duties,' STP committed in the
FSAR to relieve the shif t supervisor of administrative burden
through delegation of non safety duties to a control room
administrative aide. To implement this commitment, the plant
organization was changed by the inclusion of a job description for
an Administrative Aide position in the STP plant policy
OPCP01 ZA-0001, " Nuclear Plant Organization Policy". The job
description did not receive a licensing compliance review or specify
that the Administrative Aide was to be available during all shifts.
STP initially employed administrative aides covering each of the
Unit I shif ts, including weekend and back shif t coverage. This
coverage was consistent with the SER.
Each shift had an
administrative aide who relieved the shift supervisor of routine
administrative dut ies .
The administrative burden at that tiec was
A1/047.N19
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Attachment
ST.HL AE 3667
Page 2 of 2
quite heavy due to the STP Unit 1 operating licensing process.
As Unit 2 licensing and startup activities began to peak, additional
control room aides were exployed to handle the work loads for both
Unit .
Once both units had completed startup testing and begun
powe. production, the administrative workload (procedure revisions,
plant modifications, etc.) had decreased significantly.
The
necessity for full shift coverage was evaluated and it was concluded
that such coverage was no longer necessary.
As a result, coverage
was reduced to Honday through Friday, 0600 to 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />.
HlAP has investigated the circumstances through which this
organizationni change was made without it being reconciled with the
The organizational change did not receive the same
rigorous and formal scrutiny given other f acility changes.
Consequently the inconsistency with the SER was not identified.
III.A.
Corrective Aq11on Taken and Results Achieved
Review of other organizational changes revealed that HL&P had made
an organization change concerning the Plant Operations Review
Committee (PORC) composition which deleted the position of Plant
Superintendent, a position required by Technical Specification (TS) 6.5.1.2.
Although a Technical Specification Change Request had
been submitted to the NRC, the PORC membership was changed prior to
receipt of the NRC
approved amendment.
However, PORC meetings
remained in compliance with the quorum required by TS 6.5,1.5.
Further review found no other discrepancies with licensing
'
docunents.
As an interim corrective measure, a directive has been issued to
reinforce the importance of assuring that or6anizational changes
receive appropriate compliance review.
IV.A.
Corrective Steps Taken to Prevent Recurrence
lhe STPECS commitment tracking practices are thorough and ef fective.
There have been no significant findings of non compliance which
would lead to a concern beyond the organizational changes
identified.
For further assurance, HL&P will evaluate the review
and control of such changes to ensure FSAR/SER commitments are
maintained.
It is expected that this evaluation will be completed
by March 31, 1991.
Any measures determined necessary will be
scheduled for implementation at that time.
V.A.
Date of Full Compliance
!
HL&P believes that the present coverage meets the intent of
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TMI-Action l'A.1.2 and the UFSAR and will request NRC concurrence
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with this change under seperate cover.
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