ML20138J007
| ML20138J007 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/08/1985 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| OL-A-076, OL-A-76, NUDOCS 8510290213 | |
| Download: ML20138J007 (4) | |
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September 9,1982$dh'['
ST-HL-AE-883 File No. G2.4 Mr. John T. Collins Regional Administrator, Region IV U.S. Nuclear Regulatory Ccmmission 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 II, 1982.
If you should have any questions regarding this matter please contact Mr. Michael E. Powell at (713) 877-3281.
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'D Houston Lighting & Power Company September 9, 1982 cc:
G. W. Oprea, Jr.
ST-HL-AE-883 J. H. Goldberc File No. G2.4 J. G. Dewease' Page 2 J. D. Parsons D. G. Barker
.C. G. Robertson R. A. Frazar J. W. Willians R. J. Maroni J. E. Geiger H. A. Walker S. M. 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 RMS Director, Office of Inspectinn & Enforcement Nuclear Regulatory Comission Washington, D. C. 20555 G. W. Muench/R. L. Range Charles Bechhoefer, Esquire Central Power & Lic5t Company Chaiman, Atonic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory fennissinn Corpus Christi, Texas 78403 Washington, D. C.
20555 H. L. Peterson/G. Pokorny Dr. Janes C. Lanb. III City of Austin 313 Woodhaven Poad P. O. Box 1088 Chapel Hill, Nor t'. Carolina 27514 Austin, Texas 78767 J. B. Poston/A. vonRosenberg Mr. Ernest E. hill City Public Service Board Lawrence Livemore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808 L-46 Livermore, California 94550 Brian E. Berwick, Esquire William S. Jordan, III Assistant Attorney General Hamon & Weiss for the State of Texas 1725 I Street, N. W.
P. O. Box 12548 Suite 506 Capitol Station Washington, D. C.
20006 Austin, Texas 78711 Lanny Sinkin Citizens for Equitable Utilities, Inc.
Citizens Concerned About Nuclear Power c/o Ms. Pegoy Buchorn 5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233 Brazoria, Texas 77422 Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Comission Washington, D. C.
20555 Revision Date 08-23-82 1
<a SOUTH TEXAS PROJECT Response to Notice of Violation 50-498/82-02 50-499/82-02 I.
Statement of Apparent Violation 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 regulatien 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:
Date Initial Date of First i
Title Notification Interim Report
" Computer Program Verification" (CPV)
May 8, 1981 June 5, 1981
" Heating, Ventilation and Air Conditioning Design" (EVAC)
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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
}
II.
Houston Lighting & Power Company Response i
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 CFR 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 j
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 l
determined to be potentially reportable pursuant to 10 CFR 50.55(e) based on l
the detailed findings of the Quadrex Report which became available on May 7, 1981, and subsequently reported to NRC-0IE on May 8, 1981.
HL&P believes that it is not clear that there was a failure to report the CPV deficiency in accordance with the time limits of 10 CFR 50.55(e). HL&P became aware that there might be a problem in CPV relating to Control Room dose calculations but this item was evaluated and determined not reportable pursuant to 10 CFR 50.55(e) in December, 1980. Also in December, 1980 Brown l
4 Root (B&R) orally informed HL&P that a BAR audit had found CPV problems, but did not provide any details. (When issued the B&R vritten Audit Deficiency Report specifically stated that the CPV problems were not reportable.) As a result, in December, 1980 BAR management was requested to further investigate the matter. In addition, in January 1981, Quadrex was l
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directed to include CPV in their review.
However, EL&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-ole Region IV on May 8, 1981.
Notwithstanding the above I
described events, it should be emphasized that HL&P has instituted and completed actions as described below that would address any necessary codrective actions.
t
- 1) Corrective Steps Which Have Been Taken And The Results Achieved l
As described below, deficiency reporting procedures have been revised and employees have been retrained in order to reduce the i
potential for a failure to comply with the reporting requirements of 10 CFR 50.55(e).
During the time period following notification of NRC of these deficiencies. EL&P conducted special training to reinstruct personnel in the STP Engineering, Quality Assurance, Nuclear Plant Operations, Nuclear Services and Nuclear Fuels organizations in the identification, evaluation and reporting of deficiencies.
The
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scope, requirements and potential reportability aspects of 10 CFR 50.55(e) were emphasized. On June 12, 1981, the method for i
internal review of deficiencies was streamlined by requiring deficiencies to be reported directly to the Incident Review Committee (IRC) Chairman for review by the IRC.
i l
HL&P has also recently revised the procedure for identification, evaluation and reporting of deficiencies pursuant to 10 CFR 50.55(e)
(Project Licensing Procedure, PLP-02) to further strengthen and i
clarify HL&P's system for handling potentially reportable problems.
HL&P conducted training sessions for all personnel involved in identification, evaluation, or reporting of deficiencies immediately prior to issuance of the revised procedure, i
l 2) l Corrective Steps Which Will Be Taken To Avoid Further Violations
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HL&P will hold future training sessions to review the reporting requirements of 10 CFR 50.55(e) in order to instruct new employees in the identification, evaluation, and reporting of deficiencies.
- 3) Date When Full Compliance Will Be Achieved HL&P is now in full compliance.
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