ML20148J830

Discusses Review of Util Revised Oqap, for Plant, Units 1 & 2.Based on Review,Staff Identified Areas Needing Rev or Addl Info.Comments on Subj Plan Encl

ML20148J830
Person / Time
Site:	South Texas
Issue date:	06/13/1997
From:	Alexion T NRC (Affiliation Not Assigned)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
TAC-M92450, TAC-M92451, NUDOCS 9706170276
Download: ML20148J830 (6)

Text

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~ l June 13, 1997 Mr. William T. Cottle l

Executive Vice-President &

General Manager, Nuclear i Houston Lighting & Power Company South Texas Project Electric Generating Station I P. O. Box 289 Wadsworth, TX 77483 l

SUBJECT:

REVIEW OF REVISED OPERATIONS QUALITY ASSURANCE PLAN (0QAP), SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M92450 AND M92451)

Dear Mr. Cottle.

The Nuclear Regulatory Commission (NRC) staff is reviewing Houston Lighting &

Pcwer Company's (HL&P's) Revised Graded Quality Assurance 0QAP, dated May 21, 1997. Based on its review, the staff has identified areas needing revision or additional information (enclosed).

Should you have any questions, please contact Suzanne Black at (301) 415-1017.

Sincerely, ORIGINAL SIGNED BY:

Thomas W. Alexion, Project Manager Project Directorate IV-1 //,

\ Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation [ )l Docket Nos. 50-498 and 50-499

Enclosure:

Comments on May 21, 1997 Revised 0QAP cc w/ encl: See next page (fo/ ,

DISTRIBUTION:

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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30666 4001 j

\*..+ 1 l June 13,1997 t

Mr. William T. Cottle Executive Vice-President &

General Manager, Nuclear l Houston Lighting & Power Company . I South Texas Project Electric '

Generating Station

. P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

REVIEW 0F REVISED OPERATIONS QUALITY ASSURANCE PLAN (00AP), SOUTH

TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M92450 AND M92451)

Dear Mr. Cottle:

The Nuclear Regulatory Commission (NRC) staff is reviewing Houston Lighting &

Power Company's (HL&P's) Revised Graded Quality Assurance 0QAP, dated May 21, i

1997. Based on its review, the staff has identified areas needing revision or ,

additional information (enclosed). .

)

Should you have any questions, please contact Suzanne Black at (301) 415-1017.  !

I Sincerely, j l

gnpy . 'J Thomas W. Alexion, Project Manager j Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

Comments on May 21, 1997 Revised 0QAP cc w/ encl: See next page l

4 l

l l Mr. William T. Cottle Houston Lighting & Power Company South Texas, Units 1 & 2 cc:

Mr. David P. Loveless Jack R. Newman, Esq.

Senior Resident Inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

P. O. Box 910 Washington, DC 20036-5869 Bay City, TX 77414 Mr. Lawrence E. Martin Mr. J. C. Lanier/M. B. Lee General Manager, Nuclear Assurance Licensing City of Austin Houston Lighting and Power Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 Austin, TX 78704 Rufus S. Scott l Mr. M. T. Hardt Associate General Counsel l Mr. W. C. Gunst Houston Lighting and Power Company l

City Public Service Board P. O. Box 61867 P. O. Box 1771 Houston, TX 77208 l San Antonio, TX 78296 l Joseph R. Egan, Esq. i Mr. G. E. Vaughn/C. A. Johnson Egan & Associates, P.C.

Central Power and Light Company 2300 N Street, N.W.

P. O. Box 289 Washington, DC 20037 Mail Code: N5012 Wadsworth, TX 74483 Office of the Governor l ATTN: Andy Barrett, Director INP0 Environmental Policy Records Center P. O. Box 12428 l

700 Galleria Parkway Austin, TX 78711

, Atlanta, GA 30339-3064 l Arthur C. Tate, Director i Regional Administrator, Region IV Division of Compliance & Inspection U.S. Nuclear Regulatory Commicsion Bureau of Radiation Control 611 Ryan Plaza Drive, Suite 400 Texas Department of Health Arlington, TX 76011 1100 West 49th Street  ;

Austin, TX 78756 Dr. Bertram Wolfe '

15453 Via Vaquero Texas Public Utility Commission Monte Sereno, CA 95030 ATIN: Mr. Glenn W. Dishong 7800 Shoal Creek Blvd.

Judge, Matagorda County Suite 400N Matagorda County Courthouse Austin, TX 78757-1024 1700 Seventh Street Bay City, TX 77414  ;

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OPERATIONS OVALITY ASSURANCE PLAN (00AP)

COMMENTS ON MAY 21. 1997 DRAFT SUBMITTAL Based on the Nuclear Regulatory Commission's (NRC's) review of the Houston Lighting & Power Company's (HL&P) draft submittal of the Graded Quality Assurance 00AP, dated May 21, 1997, the following comments have been developed:

1. " Definitions", p. 4 of 10 - The definition of " critical characteristics" needs to be revised tc be consistent with the definition given in 10 CFR 21.3.

2. Chapter 1.0, 65.1.4.2, p. 3 of 4 - What are the full responsibilities of the Manager, Risk Management & Industrial Relations?

3. Chapter 2.0, 63.1, p.1 of 15 " Station economics" should not be a factor in considering the safety needs for a nuclear power plant.

4. Chapter 2.0, 52.2, p. I of 15 - Please provide explanatory words for J including "(except design and fabrication of NRC certified radioactive waste shipping casks)." l

5. Chapter 2.0, 65.3.3, p. 4 of 15 - Add " Initial evaluations are performed by the Working Group." to the end of the paragraph. 1

6. Chapter 2.0. 65.3.5, p. 4 of 15 - After "are" in the first sentence, add

" developed by the Working Group and are." l

7. Chapter 2.0, 55.3.10, p. 5 of 15 - After " experience", add "that could result in recategorization of any SSC." In the next sentence after ,

"are", add "also used." (These suggested changes provide an acceptable j response to Question #9 of NRC's 04/14/97 letter).

8. Chapter 2.0, RQlE, p. 5 of 15 - It appears that this note is redundant l to 55.3.9 above.

9. Chapter 2.0, Table I, p.14 of 15 - For the BASIC program exception to 612 of ANSI N45.2.13-1976, add "for audit of suppliers" after "necessary."

10. Chapter 13.0, p.4 of 4 - Add a new $5.8 as follows to provide an i acceptable response to Question #4 of NRC's 04/14/97 letter:

"5.8 For medium and low safety significant SSCs treated by the BASIC program controls, measures shall be established to conduct apparent cause determinations and to trend failures to assist in evaluating the need for more detailed root cause analyses (if excessive failures occur) and proper corrective action. Further, particular consideration will be given to assessing the potential implications of such failures generically to similar SSCs treated by the FULL program."

ENCLOSURE

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11. During the May 5-8, 1997, site visit NRC expressed concern that placing

. components with a risk achievement worth (RAW) greater than 10 but less than 100 in the Basic program may be inappropriate. NRC requested that HL&P identify this population of components in the QA program description, and describe how specific QA controls would be assigned to the components' critical attributes. NRC has not found a satisfactory resolution to this concern in the May 21, 1997, revised submittal. NRC requests that STP change the QA program description to:

l include a clear definition of the population of components in question. These components are currently categorized as medium-safety-significant which provides no distinction from other medium-safety-significant populations. NRC is willing to consider the acceptability of a definition of this population which does not include numerical guidelines in the 00AP, but the basic attributes of the population (e.g., high reliability yet a high impact on risk if problems develop) must be clearly described.

provide a description of how QA controls will be assigned to the i

critical attributes of this population of components. As discussed, l l NRC does not find that simple application of Basic program controls  !

is sufficient. Nor does NRC find that explicit consideration by the l working group and expert panel of the assigned controls'is sufficient. NRC is willing to consider the acceptability of assigning Full program controls to those critical component attributes which cause the component to belong to this population.  !

l l Another alternative is to simply assign these components to the high- .

safety-significant category based on the sensitivity of plant risk on  !

l their performance and place them in the FULL program. Other alternatives may also be suggested.

l 12. Although not discussed during the May 5-8, 1997, site visit, discussion l among the NRC on the acceptability of your proposed categorization i scheme has raise the question of why a high Fussell-Vesely (FV) value should not also lead to a high-safety-significant categorization regardless of the RAW. Please provide your position with respect to l

this issue.

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13. Practices and activities to ensure quality of the South Texas PRA are an important element in justifying use of risk insights as part of the GQA program. It is the staff's understanding that current CDF and LERF values are approximately an order of magnitude lower than in the 1989 (CDF) and 1992 (LERF) baseline studies. Please provide details of processes to ensure that the PRA updates and modifications were

! correctly implemented. This should include:

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- a listing of the modifications made to the PRA, the reason for each

change and a discussion of the impact on the plant's risk profile.

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quality activities to ensure that PRA revisions were correctly identified, modeled, verified, tracked and implemented.

14. During the May 5-8, 1997, site visit, you discussed an audit of your PRA contractors QA program. Please provide the results of the audit or assessment of the QA program of your PRA contractor.

l 15. In your response to RAI G-1 under cover letter dated October 30, 1996, you wrote that, "recently program procedures were developed to implement l Appendix B features to establish configuration control of the PSA models." We note that we have received four procedures by letter dated May 22, 1997. The May 22, 1997, cover letter also stated that the l

" Configuration Control of the Probabilistic Safety Assessment Procedure" has been deleted. Please provide us with the procedures which will implement Appendix B features to establish configuration control of the l PRA models, or idertify which of the four procedures is intended to provide that control.

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