ML20127D495

Notice of Violation from Insp on 920705-0801.Violation Noted:Procedure 2P0P02-HE-0001 Determined to Be Inappropriate to Circumstances

ML20127D495
Person / Time
Site:	South Texas
Issue date:	09/10/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20127D481	List: IR 05000498/1992024 ML20127D478 ML20127D495
References
50-498-92-24, 50-499-92-24, NUDOCS 9209150070
Download: ML20127D495 (2)

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4 APPENDIX A NOTICE OF VIOLATION

' Houston Lighting & Power Company Docket Nos.: 50-498 50-499 South Texas Project, Units 1 and 2 License Nos.: NPF-76 NPF-80 During an NRC inspection conducted July 5 through August 1, 1992, two violations of NRC requirements were identified. In accordance with the

" General _ Statement of Policy and Procedure for NRC Enforcement Actions," '

10 CFR Part 2, Appendix C (Enforcement Policy), the violations are listed below:

A. Failure to Have Appropriate Procedures

- Technical Specification 6.8.1.a requires that written procedures shall be ,

established,-implemented, and maintained covering those_ activities recommended in. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires, _ in part, _ that activities affecting _ quality shall be prescribed by l procedures of a type appropriate to the circumstances. One example of violating this requirement -is stated below:

1. Regulatory Guide 1.33, Appendix A, item 3.P, requires procedures for the control room heating and ventilation system. 'This is implemented, in part, by Procedure-2P0P02-HE-0001, Revision 2, " Electrical 2 Auxiliary Building HVAC System,"

Step 9.0 of Procedure 2 POP 02-HE-0001 requires returning the Electrical

< Auxiliary Building / Control Room to a normal operating configuration after an actuation.-

Contrary to the above, Procedure 2P0P02-HE-0001 was determined to be inappropriate to the circumstances. As a result, on June 3, 1992, reactor operators performing a system restoration of the control room envelope following a system actuation did not properly perform the

. restoration-because an outside air makeup- supply flow control damper, FCV-9585, was_not listed in Procedure 2 POP 02-HE-0001. Damper FCV-9585 remained-open at the. time that a surveillance procedure was signed off as'having been satisfactorily completed even though the damper was

required to be in the closed position.

This is-a Severity Level-.IV violation. (Supplement I) (499/9224-02)

B. Inadeauate Corrective Actions 10 CFR Part.50, Appendix B, Criterion XVI, " Corrective Action," states in part, that measures shall be established to assure that conditions adverse. to

- quality, such as failures, malfunctions, deficiencies, deviations, defectDe material and equipment, and nonconformances are promptly identified and okodaPDR 3

.: i i-

.p i corrected. This is accomplished, in part, by Interdepartmental Procedure

-IP-1.45Q, " Station Problem Reporting."

Station Problem Report _920013 identified that cautions were determined to be required, as a minimum, to reduce the chances of essential chilled water flow

-switch malfunction during the valving in-process following maintenance.

Contrary to the above, on July 17.-1992, the licensee had not incorporated the required cautions-into the applicable maintenance program procedures even

- though this action was identified in May 1992. The corrective action was not taken because of a miscommunication as to which department wcs going to take responsibility for completion of the assigned activities.

This is a Severity Level IV violation (Supplement 1) (498;499/9224-01)

Pursuant to-the provisions of 10 CFR Part 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional- Administrater, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the-letter transmitting .this Notice. This reply should be clearly marked as a " Reply to a Notice of Violatien" and should include for each violation: (1) the reason for th~e violation, or if contested, the basis _ for disputing the violation; (2) the corrective steps that'have_been_taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Commission'may issue an order or demand for information as to why the license should not be modified,-suspended, or

' revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration will-be given to extending the response time.

Dated at Arlinoton exas, this/5fLday of 992-I"

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