ML20205F915
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| ML20205F915 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/26/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8703310332 | |
| Download: ML20205F915 (1) | |
See also: IR 05000498/1986033
Text
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MAR 2 61987
1:
In Reply Refer To:
Dockets: 50-498/86-33
Houston Lighting & Power Company
ATTN: J. H. Goldberg, Group Vice
President, Nuclear
P. O. Box 1700
Houston, Texas 77001
Gentlenen:
Thank you for your letter of March 5,1987, in response to our letter and
Notice of Deviation dated February 6, 1987. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Deviation. We will
review the implementation of your corrective actions during a future inspection
to determine that full compliance has been achieved and will be maintained.
Sincerely,
Orlp,inal Signed By
E. H. Jch=n
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Houston Lighting & Power Company
ATTN: M. Wisenberg, Manager,
Nuclear Licensing
P. O. Box 1700
Houston, Texas 77001
Texas Radiation Control Program Director
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March 5, 1987
ST-HL-AE-1945
File No. G2.4, Y17
(8633/01)
10CFR2.201
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U. S. Nuclear Regulatory Commission
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Attention: Document Control Desk .:
Washington, DC 20555 la MAR i 21987
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South Texas Project ,f
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Units 1 and 2 !
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Docket Nos. STN 50-498, STN 50-499 --~ -
Response to Notice of Deviation (498/8633-01)
Houston Lighting & Power Company has reviewed Notice of Deviation
* 86-33-01 dated February 6, 1987 and submits the attached response pursuant to
10CFR2.201.
If you should have any questions on this matter, please contact Mr.
S. M. Head at (512) 972-8392.
'
.
J. H. Goldberg
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Group Vice President, Nuclear
SDP/hg
Attachments: Response to Notice of Deviation (498/8633-01)
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ST-HL-AE-1945
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Houston Lighting & Power Company
(8633/01)
Page 2
cc:
Regional Administrator, Region IV M.B. Lee /J.E. Malaski
Nuclear Regulatory Commission City of Austin
611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088
Arlington, TX 76011 Austin, TX 78767-8814
N. Prasad Kadambi, Project Manager M.T. Hardt/A. von Rosenberg
U.S. Nuclear Regulatory Commission City Public Service Board
7920 Norfolk Avenue P.O. Box 1771
Bethesda, MD 20814 San Antonio, TX 78296
Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
7920 Norfolk Avenue 1717 H Street
Bethesda, MD 20814 Washington, DC 20555
Dan R. Carpenter
Senior Resident Inspector / Operations
c/o U.S. Nuclear Regulatory
Commission
P.O. Box 910 '
Bay City, TX 77414
Claude E. Johnson
Senior Resident Inspector /STP
c/o U.S. Nuclear Regulatory
8
Commission
P.O. Box 910
Bay City, TX 77414
M.D. Schwarz, Jr., Esquire
Baker & Botts
One Shell Plaza
Houston, TX 77002
J.R. Newman, Esquire
Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036
T.V. Shockley/R.L. Range
Central Power & Light Company
P. O. Box 2121
Corpus Christi, TX 78403
L4/NRC/nd/hg-0 Revised 2/3/87
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Attachmsnt
ST-HL-AE-1945
File No. G2.4, Y17
'
(8633/01)
Page 1 of 3
South Texas Project
Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Deviation (498/8633-01)
I. Statement of Deviation
Based on the results of an NRC inspection conducted November 2, 1986,
through January 2, 1987, a deviation from your commitments was
identified. The deviation consisted of failure to make available
preoperational test procedures for NRC review within approximately 60
days of scheduled testing. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix
C (1986), the deviation is listed below:
HL&P Final Safety Analysis Report, Section 14.2.11.5, Amendment 53,
states, in part, "It is planned to have preoperational and initial
startup test procedures available for examination by interested
parties approximately 60 days prior to their scheduled use in the
field, and not less than 60 days prior to fuel load."
In deviation from the above, Preoperational Test Procedure
1-RC-P-02, " Hot Functional Test (HFT)," Revision O was issued to the
t NRC on November 19, 1986, and scheduled for performance to commence
on January 15, 1987, (57 days later) without the 86 modified
operating procedures and 5 support preoperational test procedures
necessary to perform the HFT. These supporting documents had not
been made available to the NRC staff on January 2,1987. The HFT
was scheduled to begin in January 1987. (498/8633-01)
Houston Light & Power Company is hereby requested to submit to this
office within 30 days of the date of the letter transmitting this Notice,
a written statement or explanation in reply including for the deviation:
(1) the reason for deviation if admitted, (2) the corrective steps which
have been taken and the results achieved, (3) the corrective steps which
will be taken to avoid further deviations, and (4) the date when full
compliance will be achieved. Where good cause is shown, consideration
will be given to extending the response time.
II. Reason for Deviation
Preoperational Test Procedure 1-RC-P-02 Hot Functional Test (HFT),
Revision 0 was submitted November 19, 1986, approximately 52 days prior
to actual start of HFT on January 10, 1987. The 86 modified Operating
,
Procedures mentioned in the Notice of Deviation are references within the
Preoperational Procedure. The reference material, (i.e., modified
procedures) was not provided to the NRC with the Preoperational Test
Procedure. It was not our intent to make the modified operating
L4/NRC/nd/hg-0
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Attichm2nt
ST-HL-AE-1945
File No. G2.4, Y17
4
(8633/01)
Page 2 of 3
procedures available, until it was possible to reflect the actual plant
configuration. The modified operating procedures were not issued in the
marked up form until approximately 10 days before the start of Hot
Functional Testing. These procedures reflect actual plant configuration
at the time of HFT.
The five HFT support Preoperational Procedures mentioned in the Notice of
Deviation were submitted late primarily because of late data input.
III. Corrective Action Taken and Results Achieved
All HFT support Preoperational Procedures are available for examination
by interested parties and have been reviewed by the site resident NRC
inspector (s). Resolution of the NRC comments on Revision 0 of the HFT
was completed prior to start of HFT.
IV. Corrective Steps Taken to Prevent Recurrence
The following Peoperational Test procedures will not be approved within
the FSAR stated window:
Procedure # Title
t 1-WS-P-02-00 -Spent Resin Storage Tank
1-US-P-01-00 -Solid Waste Processing System
1-WL-P-03-00 -Liquid Waste Process
1-BR-P-01-00 -Boron Recycle System
1-SP-P-03-00 -Reactor Trip & ESF Time Response
1-RA-P-18-00 -System Communication
1-RA-P-05-00 -Condenser Vacuum Pump WRGM
l-ED-P-02-00 -RCS Liquid Leak Detection
1-FW-P-01-00 -Feedwater System Safety Related
Valves and Control
1-SF-P 01-00 -Safeguards Systems Response No
Blackout
1-SF-P-02-00 -Safeguards Response Plant
Blackout
These procedures have been identified to the resident inspector and draft
procedures will be provided to facilitate NRC review and resolution of
comments.
Unit 2 procedures, including the incorporation of Test Change Notices,
will be prepared directly from the Unit 1 preoperational procedures.
Therefore, the Unit 2 preoperational and initial startup test procedures
will be available for examination by interested parties approximately 60
days prior to their scheduled use in the field, and not less than 60 days
prior to fuel load.
L4/NRC/nd/hg-0
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Attachmsnt
ST-HL-AE-1945
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File No.: G2.4, Y17
I (8633/01)
Page 3 of 3
V. Date of Full Compliance
STP is currently in compliance with regulatory requirements in that the
HFT support preoperational test procedures have been made available for
examination, and resolution of NRC comments has been completed.
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