ML20151Z998

Ack Receipt of 880415 Response to NRC 880318 Notice of Violation.Requests Addl Info on When Surveillance Test Becomes Quality Record in Event That as Found Test Condition Not Acceptable Per 880502 Telcon W/ Head

ML20151Z998
Person / Time
Site:	South Texas
Issue date:	05/03/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8805060031
Download: ML20151Z998 (2)

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MAY 3 1988

~ -In Reply _ Refer To:

Dockets: 498/88-07 50-499/88-07 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 April 15, 1988, in response to our letter and the attached Notice of Violation dated March 18, 1988. As a result of our review, we find that additional information, as discussed with your Mr. S. Head during a telephone call on May 2, 1988, is needed. Specifically, we request that you provide additional information on when a surveillance test becomes a quality record in the event that the "as found" test condition is not acceptable.

Please provide the supplemental information within 30 days of the date of this letter.

Sincerely, Original Signed By L. J. Callan L. J. Callan, Director Division of Reactor Projects cc:

Houston Lighting & Power Company ATTN: M. A. McDurnett, Manager Operations Support Licensing P.O. Box 289 Wadsworth, Texas 77483 Houston Lighting & Power. Company ATTN: Gerald E. Vaughn, Vice President Nuclear Operations P.O. Box 1700 Houston, Texas 77001 Houston Lighting & Power Company ATTN: S. L. Rosen P.O. Box 289 Wadsworth, Texas 77483 L 0:DRP b Reconcur RIV:RI

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Houston Lighting & Power. Company cc'(cont'd):.

Central Power & Light Company ATTN: R..L. Range /R. P. Verret P.O. Box 2121

. Corpus Christi, Texas 78403 City Public' Service Board

. ATTN: R. J. Costello/M. T. Hardt P.O. Box 1771-San Antonio, Texas 78296.

City of-Austin Electric Utility ATTN: R. J. Miner, Chief Operating Officer 721 Barton Springs Road Austin, Texas 78704 Texas Radiation Control Program Director bec:

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DRP. RRI-0PS R. D. Martin, RA DRS SectionChief(DRP/0) RPSB-DRSS MIS System RIV File Lisa Shea, RM/ALF RSTS Operator R. Bachmann, OGC D. Hunnicutt P. Kadambi, NRR Project Mana p r TSS H. Scott, Acting EO

' R. Stewart I. Barnes

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l The Light company P.O. Box 1700 Houston. Texas 77001 (713) 228 9211 i Houston Lighting & Power i I

April 15, 1988 1 4 l 10CFR2.201 iI APff 211988 lj i:

- j U. S. Nuclear Regulatory Comission Attention: Document Control Desk -

Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Reply to Notice of Violation 8807-01 Houston Lighting & Power Company has reviewed the Notice of Violation included in Inspection Report 88-07 and submits the attached response pursuant to 10CFR2.201.

If you should have any questions, please contact Mr. M. A. McBurnett at (512) 972-8530.

r J. H. Goldberg Group Vice President, Nuclear JHG/MAM/is

Attachment:

Reply to Notice of Violation 8807-01 l

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I A Subsidiary of Houston Industries incorporated 0 0 n' i / A O /A///^ ! -

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Houston Lighting & Power Company ST-HL-AE-2614 File No.: G2.4 Page 2 Cc3 Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associated 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 INPO 1 White Flint North Records Center 11555 Rockville Pike 1100 circle 75 Parkway Rockville, MD 20859 Atlanta, Ga. 30339-3064 Dan R. Carpenter Dr. Joseph H. Hendrie Senior Resident Inspector / Operations 50 Be11 port Lane e/o U. S. Nuclear Regulatory Commission Be11 port, NY 11713 P. O. Box 910 Bay City, TX 77414 Don L. Garrison Resident Inspector / Construction 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 R. John Miner (2 copies)

Chief Operating Officer City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 -

R. J. Ccstello/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 4

Revised 03/18/88 NL.LER.DIST.1&2

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Attechmsnt ST-HL-AE-2614 Page 1 of 2 South Texas Project Electric Generating Station ,

Unit 1 Docket No.- SIN 50-498 Reply to Notice of Violation 8807-01 I. Statement of Violation Failure to Designate a Record Custodian and Properly Control Records While in a Temporary Working File 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, states, in part, "..... Consistent with applicable regulatory ,

requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned ,

responsibility." Section 6.10, "Record Retention," of the STP Technical Specification, paragraph 6.10.2, states, in part, "The following records shall be retained for a least 5 years:.....d. Records of surveillance activities, inspections, and calibrations required by these Technical Specifications." i STP Procedure OPGP03-ZA-0042, "Operations Quality Records," dated  ;

December 31, 1987, paragraphs 4.3.4 and 4.3.5 require designating a l record custodian responsible for the control of records while in a division quality assurance record file and establish the maximum retention time as 90 days.

Contrary to the above, on January 27, 1988, surveillance test records in the engitaering department division record file were found to be lacking i required record retention control. A record custodian with the I responsibility for the control of records while in the division file had not been designated and procedures did not exist to control access to the division file.

II. Houston Lighting and Power Position ,

i Houston Lighting and Power concurs that the cited violation occurred.

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III. Reason for Violations t

The root cause for the violation involved KL&P's interpretation of the i point in time when the Technical Specification (TS) survei2

• ance packages become a Quality record. After the data is obtainedr several 7 l signatures are obtained on the test package cover sheet including the l test coordinator and second party reviewer. ML&P had considered the TS '

surveillance package to be a Quality record at the point when the last  !

, signature was applied to the package. A TS surveillance package is now  ;

i considered to be a Quality record when credit is taken for the l L surve ill anc e , i.e., when the test coordinator signs attesting that the  !

acceptance criteria have been met and that the TS surveillance package is complete and legible,

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NL.88.098.01 l

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Attechm:nt 1 ST-HL-AE-2614 )

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l IV. Corrective Action Taken And Results Achieved The following actions were taken to provide interim storage for TS i surveillance packages within Plant Engineering Department in accordance with plant procedure OPGP03-ZA-0042:

A. A lockable, one hour fire rated filing cabinet has been provided.

B. A log has been established to track the removal of TS surveillance packages and provide an index of what is maintained in the file.

C. A records custodian has been designated.

A memorandum was issued from the Plant Manager to Department / Division Management requiring that interim storage be provided for documents containing critical information, including TS Surveillatice Packages, when credit is taken for them. Divisions within the Nuclear Plant Operations Department which process TS Surveillance Packages after test coordinator approval will provide interim storage protection in accordance with OPGP03-2A-0042 for the TS Surveillance Package.

V. Corrective Steps Taken to Prevent Recurrence Plant procedure OPGP03-ZE-0004, "Plant Surveillance Program", has been revised to indicate the point at which TS Surveillance Packages are to be treated as Quality records.

VI. Date of Full Compliance HL&P is in full compliance at this time.

NL.88.098.01