ML20065N179
| ML20065N179 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/09/1982 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20065N178 | List: |
| References | |
| ST-HL-AE-883, NUDOCS 8210220125 | |
| Download: ML20065N179 (4) | |
Text
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The Light c o m P u y
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File No. G2.4
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Mr. John T. Collins Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
Dear Mr. Collins:
South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violation Pursuant to the provisions of 10 CFR 2.201 enclosed is Houston Light-ing & Power Company's response to the Notice of Violation 50-498/82-02, 50-499/82-02 dated August 11, 1982.
If you should have any questions regarding this matter p' ease contact Mr. Michael E. Powell at (713) 877-3281.
Very trul yours, 1
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a, Exe tive President MRW/aa At.tachment l
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021022012S 821014 PDR ADOCK 05000498 O
6 flouston 1.ighting & l'ower Company September 9, 1982 cc:
G. W. Oprea, Jr.
ST-HL-AE-883 J. H. Goldbero File No. G2.4 J. G. Dewease' Page 2 J. D. Parsons D. G. Barker C. G. Robertson R. A. Frazar J. W. Williams R. J. Maroni J. E. Geiger H. A. Walker S. fl. Dew J. T. Collins (NRC)
D. E. Sells (NRC)
W. M. Hill, Jr.
(NRC)
M. D. Schwarz (Baker &Botts)
R. Gordon Gooch (Baker &Botts)
J. R. Newman (Lowenstein, Newman, Reis, & Axelrad).
STP Rf15 Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C. 20555 G. W. Muench/R. L. Range Charles Bechhoefer, Esqu.re Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory fomnission Corpus Christi, Texas 78403 Washington, D. C.
20555 t
H. L. Peterson/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A. vonRosenbera Mr. Ernest E. Hill City Public Service Board Lawrence Livermore Laboratory P. O. Box 1771 University of California l
San Antonio, Texas 78296 P. O. Box 808, L-46 Livermore, California 94550 B.ian E. Berwick, Esquire William S. Jordan, III Assistant Attorney General Harnon & Weiss for the State of Texas 1725 I Street, N. W.
P. O. Box 12548 Suite 506 Capitol Station Washington, D. C.
Lanny Sinkin Citizens for Equitable Utilities, Inc.
l Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233
.Brazoria, Texas 77422 l
Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Revision Date 08-23-82 L
SOUTH TEXAS PROJECT Response to Notice of Violation 50-498/82-02 50-499/82-02 N.6 I.
Statement of Apparent Violation s
10 CFR 50.55(e) requires that the holder of a construction permit shall notify the Commission of each deficiency found in design and construction, which, if uncorrected could adversely affect the safety of plant operations.
The regulation further requires that the holder of the construction permit shall notify the appropriate NRC regional office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after.the deficiency is found.
The following deficiencies were identified and reported by the applicant:
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Date Initial Date of First
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Title Notification Interim Report di
" Computer Program
';f Verification" (CPV)
May 8, 1981 June 5, 1981 y-
" Heating, Ventilation and Air Conditioning Design" (HVAC)
May 8, 1981 June 9, 1981 Contrary to the above, these deficiencies which were found by the applicant on or about November 1980 and January 1981, respectively,' were'not reported to the Region IV ' office within the required 24 ' hours.
II.
Houston Lighting & Power Company Response Houston Lighting & Power Company (HL&P) agrees that there was a' failure to report the HVAC design deficiency in accordance with the time limit of 10 CFA.
50.55(e). HL&P became concerned with the adequacy of the~HVAC design around April 1980. However, at that time, the implications of the problem relative to reportability were not recognized. The HL&P employees knowledgeable'of this concern did not identify its existence to our Incident' Review Committee; accordingly. the problem was not evaluated pursuant to 10'CFR 50.55(e) and, therefore, was not identified as potentially_ reportable. The deficiency was determined to be potentially reportable pursuant to 10 CFR 50.55(e) based on-the detailed findings of the Quadrex Report which became available.on
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May7,1981,andsubssju6htlyreportedtoNRC-0IEonMay8,1981.
UL&P telieves that it isspot; clear that there was a failure to report the CPV deficiency in accord 3nce w(th the time: limits of 10.CFR 50.55(e). HL&P became aware thatithert might be a-problem in CPV relating'to. Control-Room?
dose'calculatinas,butthishitemwasevaluatedanddeterminednot' reportable 0
pursuantto 10 tFR'50155(e) in' December, 1980. Also in December, 1980 Brown
& Root (B&R) orallysJ,nformed HL&P that a B&R audit had found CPV. problems,.
but did not provide =any'de' tails. (When issued the B&R written' Audit Deficiency 4Repo'rtispecifically3p{ated that the CPV prbblema were not,
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reportable.) As a\\resu'It, in December. 1980 B&R management'was requested to furthet inve,stQgatethematter.
In addition,'in' January _1981, Quadrex was
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directed to include CPV in their review. However, HL&P did not have sufficient information to attach safety significance to the CPV problems until the detailed findings of the Quadrex Report became available on May 7, 1981. Therefore, no evaluation of a generic CPV problem relative to reportability or potential reportability pursuant to 10 CFR 50.55(e) could be accomplished until May 7, 1981. HL&P subsequently, reported the CPV deficiency to NRC-0IE Region IV on May 8, 1981. Notwithstanding the above described events, it should be emphasized that HL&P has instituted and completed actions as descrit.ed below that would address any necessary corrective actions.
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- 1) Corrective Sto s Which Have Been Taken And The Results Achieved
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e As descr bed below, deficiency-reporting. procedures have 'been d
s revised and employees have been' retrained in order to reduce the potent 3,al for a failure to comply with the reporting requirements of 10 CFR 50>55(e).
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s During the time period following + st;tfication of NRC of these deficiencies, HL&P conducted specSal'tratring to reinstruct x,
personnel'in the SIP Engineerihd,' Quality' Assurance, Nuclear Plant v
Operations, Nuclear Services and;t9Iglear Fuels organizations in the G,
identification, evaluatien end 5eporting of deficiencies. The
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scope,' requirements and 1 t,*ntial'reportability aspects of g
10 CFR 50.55(e) were emplusized. On June 12, 1981, the method for internal rqview oi deficiangics was s;:reamlined by requiring deficiencies to be reported directly to the Incident Review V jd6;ntaittee (IRC) Chairman for review by the IRC.
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HL&P has also recently revised the procedure for identification.
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evaluation and reporting of deficiencies pursuant to 10 CFR 50.55(e) s
( (Project Licensing Procedure, PLP-02) to further. strengthen and 4
clarify PL&P's system for handling potentially reportable problems.
HL&P conducted training sessions for all personn~el involved in
,,4 identification, evaluation, or reporting of deficiencies immediately prior to issuance of the revised procedure.
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- 2) Corrective Steps Which Will Be Taken To i-E /!
Avoid Further Violation 3
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HL&P will hold future traininh sessions to; review the reporting
. f, requirements of ID CFR 50.55(c). in order to' instruct new employees
'in the identification, evaluation, and eporting of deficiencies.
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- 3) Date When Full CompliaSt.e'Will Be Achieved
- 4 HL&P is now in full coIp11ance.
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