ML20148H985
| ML20148H985 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/22/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8803300135 | |
| Download: ML20148H985 (2) | |
See also: IR 05000498/1987077
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In Reply Refer To:
Dockets:
50-498/87-77
50-499/87-77
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Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P.O. Box 1700
Houston, Texas 77001
Gentlemen:
Thank you for your letter. of February. 26, 1988, in response to our letter
and Notice-of Deviation dated January 27, 1988. We have reviewed your reply
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and find it responsive to the concerns raised.in our Notice of Deviation. We
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will review the implementation of your corrective actions during a future
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inspection to determine that full compliance has been achieved and will be
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maintained.
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Sincerely,
Original < Signed IlY
L. I, Callan
L. J. Callan, Director
Division of Reactor Projects
cc:
Houston Lighting & Power Company
ATTN:
M. A. McBurnett, Manager
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Operations Support Licensing
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P.O. Box 289
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Wadsworth, Texas 77483
Houston Lighting & Power Company
ATTN: Girald E. Vaughn, Vice President
Nuclear Operations
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P.O. Box 1700
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Houston, Texas 77001
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Houston Lighting & Power
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Company
Hcuston Lighting &. Power Company
. ATTN:
S.-L. Rosen
P.O. Box 289
Wadsworth, Texas 77483
Central Power & Light Company
' ATTN:
R. L. Range /R. P.-Varret
P.O. Box 2121
Corpus Christi, Texas 78403
City Public Service Board
ATTN:
R. J. Costello/M. f. Hardt
P.O. Box 1771
San Antonio, Texas 78296
City of Austin Electric Utility
ATTN:
R. J. Miner, Chief Operating
Officer
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721 Barton Springs Road
Texas Radiation Control Program Director
bcctoDMB(IE01)
bec distrib. by RIV-
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RRI-0PS-
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R. D. Martir., RA
SectionChief(DRP/D)
RPSB-DRSS
MIS System
RIV File
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Lisa Shea, RM/ALF
RSTS Operator
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R. Bachmann, 0GC
D. Hunnicutt
P. Kadambi, NRR Project Manager
R. Hall
D. Powers
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The Light
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company
P.O. Box 1700 Houston. Texas 77001 (713) 228 9211
Houston Light.ing & Power
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February 26, 1988
ST-HL-AE-2532
File No.:
G2.04
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U.
S. Nuclear Regulatory Commission
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Attention:
Document Control Desk
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Washington, DC 20555
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South Texas Project Electric Generating Statj,on
Unit 1
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Docket No. 50-498
Response to Deviations
Included in Inspection Report 87-77
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HL&P was reviewed the Notice of Deviations ircluded in Inspection
Report 87-77 and submits the attached response pursuant to 10CiR Part 2,
Appendix C.
In addition, we have addressed your concerns relative to the Licensing
Comment Tracking System in Attachment B.
If you have any questions on this
subj e c t , please contact S. M. Head at (512) 972-8392.
M
G. E. Vaughn
Vice President
Nuclear Plant Operations
GEV/SMH/1s
Attachment A:
Response to Nott
3 of Deviations
Included in Inspi '. ion Report 87-77
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Attachment B:
Response to NRC Concern Relative to
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the Adequacy of the HL&P Licensing
Commitment Tracking Sys tem
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A Subsidiary of Houston Industries Incorporated
NL.BB.049.01
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Houston Lighting & Power Company
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ST-HL-AE-2532
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File No.: G2.04
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Regional Administrator, Region IV
Rufus S.' Scot *.
Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 1000
Houston Lighting & Power Company
Arlington, TX 76011
P. O. Box 1700
Houston, TX 77001
N. Prasad Kadambi, Project Manager
U. S. Nuclear Regulatory Commission
1 White Flint North
Records Center
11555 Rockville Pike
1100 Circle 75 Parkway
Rockville, MD 20859
Atlanta, Ga. 30339-3064
Dan R. Carpenter
Senior Resident Inspector / Operations
c/o U. S. Nuclear Regulatory
Commission
P. O. Box 910
Bay City, TX 77414
J. R. Newman, Esquire
Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036
R. L. Range /R. P. Verret
Central Power & Light Company
P. O. Box 2121
Corpus Christi, TX 78403
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R. John Miner (2 copies)
Chief Operating Officer
City of Austin Electric Utility
721 Barton Springs Road
Austin, TX 78704
R. J. Costello/M. T. Hardt
City Public Service Board
P. O. Box 1771
San Antonio, TX 78296
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Revised 02/03/88
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Attachment A
Response to Notice of Deviation
From Inspection Report 87-77
(Page 1 of 6)
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Reference 1) Letter from J. H. Goldberg to Document Control Desk Dated
July 15, 1987 (ST-HL-AE-2298)
Reference 2) Letter from G. E. Vaughn to Document Control Desk Dated
December 31, 1987-(ST-HL-AE-2467)
Deviation A.1
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A.1.I
Statement of Deviation
In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC, the
licensee responded to the findings of the operational readiness
inspection of June 29 through July 2, 1987, and the observations
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discussed during the exit interview on July 2, 1987.
The
following deviation from the commitment stated in the July 15,
1987, letter was identified:
In response to Observation No. 4, the licensee stated that,
"WCC activities are currently included in maintenance audit
plans."
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In deviation from the above, the NRC inspector found on
December 15, 1987, that the current maintenance audit plan,
"Audit D3, Maintenance Activities," dated July 13, 1987, did
not contain provisions for a review of WCC activities, and
the operations QA manager stated that he had never intended
to audit WCC activities.
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A.I.II
Reason for Deviation
The intent of HL&P commitment was that quality related maintenance
activities that could be affected by the Work Control Center (WCC)
are included in the maintenance audit plans. The statement was
not intended to imply that Nuclear Assurance would audit the WCC
specifically.
As discussed in Reference 2, audits and an assessment have been
performed which included within their scope the activities of the
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WCC and the Daily Work Activity Schedule process. We believe that
this type of review by Nuclear Assurance fulfills the intent of
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the commitment made by HL&P in Reference 1, and as such a
deviation does not exist.
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Since audits of WCC activities haue occurred, the statement made
by the QA manager was addressing the fact that he did not plan to
audit the WCC specifically.
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NL.88.049.01
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Attachment A
Response to Notice of Deviation
From Inspection Report 87-77
(Page 2 of 6)
Deviation A.1 (Cont.T
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A.I.III
Corrective Actions That Have Been Taken
Not applicable
A.I.IV
Corrective Actions That Will Be Taken
Not applicable
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A.1 V
Date When Full Compliance Will Bs Achieved
STPEGS is in full compliance at this ti$'e.
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Attachment A
Response to Notice of Deviation
From Inspection Report 87-77
(Page 3 of 6)
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Deviation A.2
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A.2.I.
Statement of Deviation
In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC, the
licensee i*esponded to the findings of the operational readiness
inspection of June. 29 through July 2, 1987, and the observations
discussed during the exit interview on July 2,1987.
The
following deviation from the commitments stated in the July 15,
1987, letter was identified:
In response to Observation No. 14, the licensee stated that,
"Since the LCO log sheet may not be visible to the other
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licensed operators in the control room, HL&P will also
require entries in the unit supervisor and control room logs
of entry into an LCO and exit from an LCO."
In deviation from the above, Control Room Procedure
OPSP03-ZQ-0001, which had been last revised (Revision 1) on
July 31, 1987, required only that the unit supervisor log
record entries of the' plant's entry into an LCO and exit from
an LCO.
The NRC inspector also found on December 15, 1987,
that the control room log did not contain entries of LCO
status.
A.2.II.
Reason for Deviation
Th'e reason for this deviatJon is that the responsible department
failed to' completely implement the commitment.
A.2.III.
Corrective Actions That Have Been Taken
A procedure change was issued to OPOP03-ZQ-0030 "Maintenance of
Plant Operations Logbooks" on December 16 requiring entries in the
reactor operators logbook (control room log).
To address the root cause'and generic implications of this
deviation, please see Attachment B.
A.2.IV
Corrective Actions To Be.Taken
No additional corrective actions are considered necessary.
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A.2 V.
Date When Full Compliance Will Be Achiev'ed
STPEGS is in full compliance at this time.
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NL.88.049.01
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Attachment A
Response to Notice of Deviation
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From Inspection Report 87-77
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(Page 4 of 6)
Deviation A.3
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Statement of Deviation
In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC, the
licensee responded to the findings of the operational readiness
inspection of June 29 through July 2,1987, .and the observations
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discussed during the exit interview on July 2, 1987. The
following deviation from the commitment stated in the July 15,
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1987, letter was identified:
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In response to Observation No. 35, the licensee stated that,
"A procedure will be written which specifies actions to be
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taken as a result of ISEG reports. This procedure will be
completed by September 30, ,1987.
As an interim measure,
plant management has directed that responses for ISEG reports
be generated by responsible managers which address pertinent
issues identified in the report."
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In deviation from the,above, the NRC inspector found on
December 15, 1987, that no response had been generated to an
ISEG report entitled, "ISEG Observation of the Work Control
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Center," and dated September 10, 1987. This report was issued
prior to the issuance of the com.aitted procedure on September
28, 1987.
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Reason for Deviation
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As noted in Reference 2 ISEG originally determined that a
response was not required. A reevaluation determined that the
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findings of the observation were serious enough to warrant a
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response.
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III.
Corrective Actions Taken
The Outage management group provided a response to the ISEG
observations on January 20, 1988.
IV.
Corrective Actions That Vill Be Taken
No additional corrective actions are considered necessary.
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Date When Full Compliance Vill Be Achieved
3TPEGS is in full compliance at this time.
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Attachment A
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Response to Notice of Deviation
From Inspection Report 87-77
(Page 5 of 6)
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Deviation B
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Statement of Deviation
In a letter (ST-HL-AE-2328), dated August 18, 1987, to the NRC,
the licensee clarified their response.as reported in their July
15, 1987, letter .for Observation No. 20.
Their revised response
stated that for the processing and investigating of anonymous tips
related to drug use, the NSD'will "contact local law enforcement
of ficials concerning the subject of the anonymous tip."
In deviation from the above, an NSD representative stated
that local law enforcement officials were contacted only when
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the allegation had been confirmed or a substantial amount of
information was provided by the anonymous alleger.
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Reason for Deviatien
This deviation was caused by a breakdown in communications between
the parties involved in establishing the subject commitment.
The
organization that submitted this commitment to toe NRC understood
that the local law enforcement would be contacted for all
anonymous tips.
In fact, the investigating organization treated
anonymous tips as indicated above.
III.
Corrective Actions Taken
HL&P has reevaluat9d the original commitment made to the NRC and
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has concluded that it is not appropriate that the local law
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enforcement be contacted for all anonymous tips. Accordingly, the
"STP Drug and Alcohol Screening Behavioral Observation Action
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Guidelines for Fitness for Duty Program" has been revised to read
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as follows:
"If the investigator determines that enough specific
information has been provided to lend credibility to the
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referral, the Sheriff's Department or other LLEA as
appropriate shall be contacted to request information which
maybe of assistance in the investigation."
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In addition, plant management has had discussions with plant
personnel to reinforce the concept that commitments must be
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accurately communicated to the NRC.
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To address the generic implication of the item, please see
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Attachment B.
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NL.88.049.01
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Attachment B
Response to NRC Concern Relative to
the Adequacy of the KL&P Licensing
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Commitment Tracking System
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Subsequent.to the. submittal of HL&P response to the initial Operational
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Readiness Inspection findings (provided at the exit) the commitments made
therein were entered on the Licensing Commitment Tracking System (LCTS). The
"status" of the completion of each commitment was monitored by upper
management on a weekly basis to ensure timely closure. A compliance type
review was not performed during this time frame to ensure that the scope and
intent of the commitments had actually been satisfied as is done for
10CFR50.5!e reports and Inspection and En,forcement Bulletins. This review
could have revealed thct commitments were in fact not complete or that
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additional clarifications should be provided to the NRC.
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Corrective Action
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"To preclude this situation occurring in the future, the following actions have
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been taken,
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The Licensing Group is performing compliance reviews for the closure of
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commitments made to the NRC via correspondence.
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Plant Management has revised the policy on Licensing Commitments
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stressing the need for accurately portraying commitme ts in
correspondence to the NRC and specifying rules whereby commitments can
be changed.
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Attachment A
Response to Notice of Deviation
From Inspection Report 87-77
(Page 6 of 6)
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Deviation B (Cont. ) -
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IV.
Corrective Actions To Be Taken
No additional actions on this issue'are required.
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V.
Date When Full Compliance Will Be Achieved
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STPEGS is in full compliancesat this time.
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