ML20198F016

Notice of Violation from Insp on 970810-1004.Violation Noted:On 970820,written Procedures Were Not Maintained Covering Operational Valve Alignment of Chemical & Vol CS in That Operators Had Utilized Equipment Clearance Order Tag

ML20198F016
Person / Time
Site:	South Texas
Issue date:	12/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198E979	List: IR 05000498/1997006 ML20198E973 ML20198F016
References
50-498-97-06, 50-498-97-6, 50-499-97-06, 50-499-97-6, NUDOCS 9801090280
Download: ML20198F016 (3)

Text

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ENCLOSURE 1_

NOTICE OF VIOLATION Houston Lighting & Power Company Dockets: 50 498 50-499 South Texas Project, Units 1 and 2 Licenses: NPF-76 NPF 80 During an NRC inspection conducted on August 10 through Octooer 4,1997, two violations of NRC regul.ements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1000, the violations are listed below:

A. Technical Specification 6.8,1 states, in part, that, written procedures shall be established, implerncnted, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A recommends, in part, that written instructions be prepared for the operation of the chemical and volume cororol system and for replacement of important filters.

Contrary to the above:

On August 20,1997, written procedures were not maintained covering the operational valve alignment of the chemical and volume control system in that operators had utilized ars equipment clearance order caution tag to change the position of a system valve from the proceduralized alignment, instead of revising the procedure. This condition contributed to an inadvertent partial draining of the volume control tank.

On August 31,1997, procedures had not been established covering the replacement of the Unit 2 spent fuel pool cooling and cleanup system filter in that operators utilized equipment clearar.ce order test tags to align the components necessary to replace the filter. This contributed to an inadvertent partial draining of spent fuel pool water inventory.

This is a Severity Level IV violation (Supplement l} (498;499/97006-01).

B. Technical Specification 4.6.1.1.a requires, in part, that primary containment integrity shall bo demonstrated at least once per 31 days by verifyi.ig that all penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions.

- Contrary to the above, from initial plant operations until August 29,1997, test, vent, and drain lines within the isolation boundary of 10 primary containment 9801090200 971200 PDR 0 ADOCK 05000498 PM

2 penetrations, not capable of being closed by operable containment automatic isolation valves and required to Le closed during accident conditions, were not verified to be closed at least once per 31 days.

This is a Severity Level IV violation (Supplement 1) (498;499/97006 04).

C. 10 CFR 50.59 states,in part, that, the holder of a license authorizing operation of a utilization f acility miy mrke changes in the f acility as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the Technical Specifications or an unreviewed safety question.

Paragraph (b)(1) further states that the licensee shall maintain records of changes in the f acility and of changes in procedures made pursuant to this section, to the extent that these constitute changes to the f acility as described in the safety analysis report. These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewad safety question.

Contrary to the above, from September 1992 until August 20,1997, the licensee f ailed to maintain records of the installation and operation of the advanced liquid c wssing system, a change to the facility as described in the safety analysis

,uort that included a wr;tten safety evaluation in that, in September 1992, the licensee fallad to evaluate se installation and operation of the system to determine if the change involved an unreviewed safety question, because plant workers had indicated that the installation and operation of the advanced liquid processing system did not constitute a change to the facility as described in the safety analysis report.

This is a Severity LevelIV violation (Supplement 1)(498;499/97006 08).

Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C, 20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of the letter transmittlag this Notice of Violation. However, the NRC has concluded that information regarding the reason for Violation A above and the corrective actions taken and planned to correct tbs violation and prevent recurrence are already 9ddressed in the enclosed report.

In addition, comprehensive corrective actions applicable to this violation were discussed in your response to Violation 498;499/97005 03. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201, if the description therein does not accurately reflect your corrective actions or your position.

The redy to Violations B and C should be clearly marked as a " Reply to a Notice of Viole.r,a" and should include for each violation: (1) the reason for the violation or, if conwrteo, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further 8

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violations, and (4) the date when full compilance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately  ;

addresses the required response. If an adequate reply is not receivod within the time specified in this Notice, an order or a Demand for Information may be issued as to why the  !

license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.'

i Because your response will be placed in the NRC Public Document Room (POR), to the extent possible, it should not include any personal privacy, proprietary, or safeguard information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please

- provide a bracketed copy of your response that identifies the information that should be

- protected and a redacted copy of your response that deletes st Th information, if you ,

request withholding of such matorial, you myg specifically identify the portions of your ,

= response that you seek to have withheld and provide in detail the bases for your claim of ,

- withholding (e.g., explain why the disclosure of information will create an Unwarrar ,ed i l Invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation), if safeguards information is necessary to provide an acceptable response, please provide the

.. level of protection described in 10 CFR 73.21.

Dated in Arlington, Texas ,

4 this 5th day of December 1997 1

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