ST-HL-AE-1337, Responds to NRC Re Violations Noted in Insp Repts 50-498/85-01 & 50-499/85-01.Corrective Actions:Records Added to File W/Missing Documentation & Record W/Improperly Located Signature Corrected,Per Startup Training Form

Responds to NRC Re Violations Noted in Insp Repts 50-498/85-01 & 50-499/85-01.Corrective Actions:Records Added to File W/Missing Documentation & Record W/Improperly Located Signature Corrected,Per Startup Training Form

ML20137Q417
Person / Time
Site:	South Texas
Issue date:	08/22/1985
From:	Goldberg J HOUSTON LIGHTING & POWER CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20137Q388	List: IR 05000498/1985001 ST-HL-AE-1337, Responds to NRC Re Violations Noted in Insp Repts 50-498/85-01 & 50-499/85-01.Corrective Actions:Records Added to File W/Missing Documentation & Record W/Improperly Located Signature Corrected,Per Startup Training Form
References
CON-#385-325 OL, ST-HL-AE-1337, NUDOCS 8509200150
Download: ML20137Q417 (4)

Text

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O The Light NE f Ilouston 1.ighting & l'ouer l'O. Box 1700 llouston, Texas 77001 (713) 228-9211 August 22, 1985 ST-HL-AE-1337 File No.: G2.4, M22.3 Mr. Robert D. Martin Regional Administrator, Region IV )) @ ][] j Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 ALE 2 6 885 Arlington, Texas 76011 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Notice of Violation 8501-01

Dear Mr. Martin:

HL&P has reviewed Notice of Violation 50-498/499-8501-01 dated July 23, 1985 and submits the attached response pursuant to 10CFR2.201.

During the resident inspector's exit on August 2, 1985, HL&P was in-formed that the subject violation will be closed in NRC Inspection Report 85-11, pending submittal of the STPEGS response.

If you should have any questions regarding this matter, please contact Ms. F. A. White at 512-972-8392.

Very truly yours, J. H. Goldberg Group Vice President, Nuclear FAW/yd

Attachment:

Response to Notice of Violation (8501-01)

[2 G

OC PD SC-ISOfd W2/NRC2/o

ST-HL-AE-1337 Ilouston Lighting & Power Company File No.: G2.4, M22.3 Page 2 cc:

Hugh L. Thompson, Jr. , Director Division of Licensing Brian E. Berwick, Esquire Office of Nuclear Reactor Regulation Assistant Attorney General for U.S. Nuclear Regulatory Commission the State of Texas Washington, DC 20555 P. O. Box Austin, TX 12548, Capitol Station 78711 N. Prasad Kadambi, Project Manager U.S. Nuclear Regulatory Commission Lanny A. Sinkin 7920 Norfolk Avenue 3022 Porter Street, N.W. #304 Bethesda, MD 20814 Washington, D.C. 20008 Claude E. Johnson Oreste R. Pirfo, Esquire Senior Resident Inspector /STP Hearing Attorney c/o U.S. Nuclear Regulatory Cocmission Office of the Executive Legal Director P. O. Box 910 Bay City, TX 77414 U.S. Nuclear Regulatory Commission Washington, DC 20555 M. D. Schwarz, Jr. , Esquire Charles Bechhoefer, Esquire Baker & Botts One Shell Plaza Chairman, Atomic Safety & Licensing Board Houston, TX 77002 U.S. Nuclear Regulatory Commission Washington, DC 20555 J. R. Newman, Esquire Dr. James C. Lamb, III Newman & Holtzinger, P.C. 313 Woodhaven Road 1615 L Street N.W. Chapel Hill, NC 27514 Washington, DC 20036 Judge Frederick J. Shon Director, Office of Inspection Atomic Safety and Licensing Board and Enforcement U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, DC 20555 Mr. Ray Goldstein, Esquire E. R. Brooks /R. L. Range 1001 Vaughn Building Central Pcwer & Light Company 807 Brazos P. O. Box 2121 Austin, TX 78701 Corpus Christi, TX 78403 H. L. Peterson/G. Pokorny Citizens for Equitabic Utilities. Inc.

c/o Ms. Peggy Buchorn City of Austin Route 1, Box 1684 P. O. Box 1088 Brazoria, TX 77422 Austin, TX 78767 Docketing & Service Section J. B. Poston/A. vonRosenberg Office of the Secretary City Public Service Board U.S. Nuclear Regulatory Commission P. O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 W2/NRC1/a Revised 5/22/85

Attachment ST-HL-AE-1337 File No.: G2.4, M22.3 Page 1 of 2 South Texas Project Units 1&2 50-498/8501-01 50-499/8501-01

1. Statement gr vigiatigg Based on the results of an NRC inspection conducted during the_ period from January 1 to February 28, 1985, in accordance with NRC Enforcement Policy (10CFR Part 2,

. Appendix C),-49.FR 8583, dated March 8, 1984, the following violation was identified:

failyre tg Prgperly Eg))pw frecedyrg Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate instructions, procedures, or drawings. This requirement is part of the approved QAPD (Quality Assurance Plan Description) for South Texas Project.

Specifically, 00AP, Section 4.0, paragraph 6.2.1.2, requires participation in a OA program indoctrination and paragraph 7.0 requires records be maintained.

Additionally, SAI (Startup Administrative Instruction) 10, " Indoctrination, Training, and Certification of Test Personnel," requires' training and certification documentation be maintained by HMS (Records Management System) with copies in the Startup Training Office.

Contrary to the above, the NRC inspector reviewed five sets of training and certification files for senior or long-term startup personnel. One file was missing a supervisor's signature and in the same file a signature was placed in the wrong location. One file had no documentation of the required QA lecture although the index stated he attended. The Startup Manager had not attended the required QA lecture which is a requirement prior to conducting safety-related activities.

II. Regly SAI 10 requires that training and certification documentation be maintained with appropriate personnel signatures. Startup personnel had improperly signed or failed to sign certification documentation which verified that self-read training was completed.

I

. . 3 i

i f

Attachment i ST-HL-AE-1337 File No.: G2.4, M22.3 Page 2 of 2 This resulted from Startup personnel inattention to the i requirements of signature on the records sheet. SAI 10 has been revised to include a modification to the startup

training form to clarify signature requirements and indicate

{ proper location of required signatures. Additionally, the individual's file, whose supervisor's signature was missing and where a signature had been placed in the wrong location, has been updated and corrected by using the modified training form which resulted from the revision to SAI 10.

I The individual whose file was missing documentation of his attendance of the OA Indoctrination Lecture had attended the f lecture on the date stated on the certification index.

Startup Training completed their review of all other Startup

! training files on March 15, 1985 and found no other i j deficiencies. The required attendance documentation was j added to his file.

J

) 00Ap Section 4.0 requires participation in the OA indoctrination program and that records be maintained of i that participation. The Startup Manager had not attended the QA indoctrination lecture as required. The Startup Manager did attend the QA Indoctrination on March 5, 1985.

Prior to this date, no safety-related testing activities had j been conducted.

III. ggrgegtive Asting Tahep gr tg he Tahep 4

l The review of the Startup training files found no other i -discrepancies; we believe this is an isolated occurrence.

The records of the individual whose file was missing documentation were located and added to the file. The

, record that contained a signature in an improper location l has been corrected in accordance with the modified startup

i training form. The Startup Manager attended QA 4

Indoctrination on March 5, 1985.

j IV. Stres Ishen 9r t9 hs 19h99 te ov91d Isrthsr V1919 1998 t

} SAI 10 has been revised to include modified Startup training j forms that clarify signature requirements. The Startup

~

Manager has re-emphasized to all Startup personnel the importance of proper QA documentation for required

training.

V. Dgle Whep 1g)) ggmpliagge Will Be Aghieved i

Full compliance was achieved on March 5, 1985.

4 l

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