ML20236D700
| ML20236D700 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/27/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8707310028 | |
| Download: ML20236D700 (2) | |
See also: IR 05000498/1987008
Text
{{#Wiki_filter:_ - - . - _ _ _ - - - - . - - - _ - - , a .Y , JUL 2 71987 In Reply Refer To: Dockets: 50-498/87-08 ' 50-499/87-08 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President, Nuclear P. O. Box 1700 Houston, Texas 77001 Gentlemen: Thank you for your letters of June 22 and July 1,1987, in response to our letter dated May 29, 1987. We have reviewed your reply and find it responsive to the concerns raised in the enclosed inspection report. We will review the implementation of your corrective actions during a future inspection to determine that satisfactory resolution of these concerns hat been achieved. Sincerely, Origna! E nmd ay J. E. Ga;iiardo J. E. Gagliardo, Chief Reactor Projects Branch cc: Houston Lighting & Pcwer Company ATTN: M. Wisenberg, Manager, Nuclear Licensing P. O. Box 1700 Houston, Texas 77001 Houston Lighting & Power Company ATTN: Gerald E. Vaughn, Vice President Nuclear Operations P. O. Box 1700 Houston, Texas 77001 Texas Radiation Control Program Director bcc: (see next page) PI Y.6 C: P C C:RPB HBundy:cs GC stable JGagli rdo ) 7/z3/87 7/d/87 7/gY8 sg 8707310029 070727 [/ PDR ADOCK 05000498 O PDR x l . - l ' i
_ _ _ _ _ _ _ _ . . Houston Lighting & Power Company -2- I bcc to DMB (IE01) bec distrib. by RIV: RPB DRSP RRI-0PS R. D. Martin, RA RRI-CONST. Section Chief (RPB/C) RPSB MIS System RIV file D. Weiss, RM/ALF RSTS Operator R. Pirfo, 0GC ' R. G. Taylor, RPB/C RSB Project Inspector, RPB R. Hall P. Kadambi, NRR Project Manager W. D. Johnson D. D. Chamberlain J. E. Cummins 1 1
_ _ _ - _ _ _ ( ' .. <> . ' The Light . NE Uf liouston Lighting & Power P.O. Box 1700 flouston. Texas 77001 (713) 228 9211 g @ $ DWY ~ JH 2 51st Jwie 22, 1987 ST-HL-AE-2268 Ma File No.: G3.12 " 10CFR50 _ U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 l Response to Inspection Report 87-08 Open Items l Reference (1) NRC Inspection Report 87-08 dated 5/29/87 (ST-AE-HL-91269) ' -(2) HL&P Letter from M. R. Wisenburg to Document Control Desk dated 2/11/87 (ST-HL-AE-1848) (3) HL&P Letter from M. R. Wisenburg to Document Control Desk dated 4/15/87 (ST-ML-AE-2080) (4) HL&P Letter from M. R. Wisenburg to Document Control Desk dated 5/15/87 (ST-HL-AE-2184) Pursuant to your request in reference (1), please find our response (Attachment 1) to open items 8708-34, 8708-61 and 8708-62. If you should have any questions on this matter, please contact Mr. l S. M. Head at (512) 972-8392. / , G. E. Vaughn Vice President Nuclear Plant Operations ELB/hg Attachment: (1) Response to Inspection Report Open Items i , , 3 , f b j i() (,/ D OJI U ' - - bP, 'O _ - L4/NRC/eb/hg-0 a & L o
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.* ST-HL AE-2268 No.:G3.12 -
Houston Lighting & Power Company p l cc: j 1 i Regional Administrator, Region IV M.B. Lee /J.E. Malaski l 'lNuclear Regulatory Commission City of Austin , , {q'jlL1RyanPlazaDrive, Suite 1000 P.O. Box 1088 3 Arlington, TX 76011 Austin, TX 78767-8814 j < N. Prasad Kadambi, Proj ect Manager A. von Rosenberg/M.T. Hardt ) U.S Nuclear Regulacory Commission City Public Service Bocrd i 7920 Norfolk Avenue P.O. Box 1771 Be,theeda, MD 20814 San Antonio, TX 78296 t
. Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards
,s U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission j 7920 Necfolk Avenue 1717 H Street ,' Bethe' da , MD 20814 Washington, DC 20555 ^*n A. Carpenter . Senior Resident Inspector /Of,erations e/o U.S. Nuclear Regulatory Commission i > P.O. Box 910 s+ , Bay City, TX 77414 9 ' ' I Claude E. J'hnson ] l Senior Resident Inspector / Construction ' { i c/o U.S. Nuclear Regulatory J l Commission' ' P.O. Box 910 Bay City, TX ??414 / M. D . Schwars , J r . , Esquire Baker 6 notts -* One Shell' Plaza Houston, TX. 77002 J.R. Newman, Esquire Newman & Holtzinger, P.C. 1615 L Street, N.W. .p Washington, DC 20036 .. 4 T.V. Shockley/R.L. Range ) Central Power 6 Light Company l - l P. O. Box 2121 1 Corpus Christi, TX 78403 4 1
e \\ , ' .. f s ' / <. t. I iL4/NRC/eb/hg-0 Revised 2/3/87 r- ,1 . l ~ l' ' . ,'l . t
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,*, .e l Attachment ' ST-HL-AE-2268
File No.:G3.12 , Page 1 of 3 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Inspection Report 87-08 Open Items 99C Open Item 8708-34: Address the steps taken to assure that all previous License Compliance Reviews have been performed properly or that controls are in place to assure that needed reevaluations / reviews are performed. STP Response: The specific concern for improperly completed License Compliance Reviews for Temporary Modifications T1-EW-8710, -8711 and -8712 has been resolved. These Temporary Modifications have been removed (equipment returned to original configurat.on as described in the FSAR). Operations Procedure OPGP03-ZO-0003 (Temporary Modifications) was revised (Rev. 6) to cause reviewers to ensure that all previous License Compliance evaluations or reviews were performed properly. Step 4.15.6 of this procedure requires active Temporary Modifications to be upgraded to comply with the requirements of this revision. These requirements include the performance of a License Compliance Review (LCR) to determine if a 10CFR50.59 Safety Evaluation is required. oOb Open Item 8708-61: Many deviations from the WOG ERGS were not documented and justified on the E0P Step Justification / Verification (SJ/V) Form. STP Response: Confirmatory Item 27, Staff review of the procedures generation package, is currently under NRC review. Telephone discussions, documented on page 13 of the attachment to Reference (1), indicate the following: HL&P is planning to assemble documentation of deviations from and additions to the WOG ERGS that will meet the intent of section 3.3.2 Appendin A of SRP 13.5.2. We further stated that we would complete this effort prior to the first refueling outage for unit 1. Subsequent conversations have indicated that the NRC Staff concurs with this completion schedule. L4/NRC/eb/hg-0 l l i
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Attachment ST-HL-AE-2268 , File No.:G3.12 ) Page 2 of 3
S O Open Item 8708-62(a): Section 3.1.2.1 of the Writers Guide required that each operator copy of an EOP present the user information and steps on the left page and the non-user information on the right page when opened. The NRC i'. , etor noted that action steps identified as being performed by the Unit Supervisor were not included with the non-user information on the right, page of the operator's copies of the E0Ps. STP Response: Our response to this item and' to your comment B.1.b in Reference (2) are addressed in a previous letter Reference (3) as follows: I The Writer's Guide (OPOP01-ZA-0006) is being revised j (Rev. 3) to the following: 3.1.2 Addenda shall be prepared for the operators to use which shall be formatted as follows: 3.1.2.1 Each operator's copy shall be identified as shown on Addendum 3. At each of the corners the abbreviations "PRI" and "SEC" shall be printed in all capitals and boxed. 3.1.2.2 Each addendum shall present those steps for the recommended operator (" USER") to accomplish on the 1 it page when the addendum is open. lhose steps not assigned shall be displayed on the right. Steps
assigned to the Supervisor shall not appear ! in the operator's addendum. ! 8708-62(b): Section 5.4 of the writers guide required maintenance of a direct horizontal relationship between.the related action steps in the left column and the contingency action steps in the right column. The NRC inspector found that the contingency action step associated with action Step 5.3 of Station Procedure 1 POP 05-EO-E010 was aligned horizontally with action Step 5.2. i l l t STP Response: The direct horizontal relationship inconsistency at ' Steps 5.3 and 5.4 of station procedure 1 POP 05-EO E010 has been corrected in the pending revision . Revision 2 will be issued prior to initial criticality of STP Unit 1 as indicated in reference (4) L4/NRC/eb/hg-0 L_-__-------_--_-_---_--_---------_-- -_ _ _ _ . _ _ _ _ _ _ - - - _ - .-.
- _ _ _ _ - - - - _ _ _ _ _ _ _ . , , * . .. , Attachment ' ST-HL-AE 2268 ' File No.:G3.12 Page 3 of 3 8708-62(c): Section 17.4 of the Writers Guide required that missing information shall be listed on a separate punchlist at the end of the written procedure body. The NRC inspector found that no punchlist was attached to Station Procedure 1 POP 05-EO-EC00 although Steps 15 and 16 of this procedure were missing information which should have been identified on a punchlist. The missing information related to contingency actions for filling the auxiliary feedwater storage tank using the fire water system and local operation of steam dump valves. STP Response: Station procedure IPOP05-E0-EC00 will be revised to include the missing information in steps 15 and 16 in lieu of revising the procedure to add the punch list at this time. Punch lists will be used in the future to identify missing information. Revision 2 will be issued pr'or to the initial criticality of STP Unit 1 as indicated in reference (4) 8708-62(d): Section 18.2 of the writers guide required that the appropriate emergency action level be entered into , the E0P at the earliest possible point. The NRC inspector found that Station Procedure 1 POP 05-EO-FHR1 contained no reference to emergency action levels which had been reached. Station Procedure OEPP01-ZA-0001, " Emergency Classification, " Addendum 3, indicated that reaching Step 9.0 of 1 POP 05-E0-FRH1 was the emergency action level for declaration of a General Emergency. STP Response: Station procedure 1 POP 05-E0-FHR1 will be revised (Rev 2) to include a caution statement preceding Step 9.0. The caution states: " REFER to OEPP-ZA-0001, EMERGENCY CLASSIFICATION. Reaching Step 9.0 represents a potential GENERAL EMERGENCY". Revision 2 is scheduled to be issued prior to initial criticality of STP Unit 1 as indicated in Reference (4), i LA/NRC/eb/hg-0 . . . .. . . . . . . . . . ._
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, . , The Light J NmPfEYiiee,'etis8<ies&reer e.o >*>x ivoo "ees<ee. Tex s 77ooi <2is> 228.e2ii ! 1 1 July 1, 1987 ST-HL-AE-2291 File No.: G3.12 ! 10CFR50 - (Yhhk [ U. S. Nuclear Regulatory Commission .I _u--- = 'l ~~' s Attention: Document Control Desk j !, I j g 9 N 1. I h Washington, DC 20555 . . . . - South Texas Project i - - " ' ' " ~ Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 " t Follow-up to Open Item 87-08-34 Reference (1) HL&P Letter from G.E. Vaughn to Document Control Desk dated 6/22/87 (ST-HL-AE-2268) (2) NRC Inspection Report 87-08 dated 5/29/87 (ST-AE-HL-91269) During a NRC site Inspection, Mr. D. Chamberlain of Region IV reviewed reference 1. Subsequently he has requested additional information to support our position on open item 87-08-34 of reference 2. Our response to that request is included in attachment 1. If you should have any questions on this matter, please contact Mr. 5. M. Head at ,512) 972-8392. y G. E. Vaughn Vice President Nuclear Plant Operations ELB/hg Attachment: (1) Response to NRC Inspector concerns b r, - 1 <, ,.hl,.,,.\\ _ r , j j fl x - ' + ' j cf _ l [[ - m up \\q L4/NRC/e1/lm-1 4' e4@
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ST-HL-AE-2291 File No.: G3.12 Page 2 cc: Regional Administrator, Region IV M.B. Lee /J .E. Malaski Nuclear Regulatory Commission City of Austin 611 Ryan Pl<.za Drive, Suite 1000 P.O. Box 1088 Arlington, in 76011 Austin, TX 78767-8814 N. Prasad Kadambi, Project Manager A. von Rosenberg/M.T. Hardt 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 M0 nager Advisory Committee on Reactor Safeguards U.S. Nuclear Reg latory 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 / Construction c/o U.S. Nuclear Regulatory Commission P.O. Box 910 1 d Bay City, TX 77414 M.D. Schvarz , Jr. , Esquire Baker & Botts One Shell Plaza Houston, TX 77002 J.R. Newman, Esquire Newman & Holtzinger, P.C. I 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 L4/NRC/el/im-1 l l l L
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Attachment 1 ST-HL-AE-2291 File No.: G3.12 Page 1 of 2 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Follow-up to Open Item 87-08-34 Note: The following Inspectors concerns (A,B & C) are paraphrased A) Temporary Modification TI-DG-87123 was written and installed without performing a License Compliance Review (LCR). STP Response: This is an isolated case. The individual who requested the Temporary Modification and his supervisor who approved the request are not Nuclear Plant Operations Department (NPOD) personnel. They have been counseled to comply with procedures. Only NPOD System Engineers are authorized to request temporary modifications. NPOD System Engineers have received additional training on the temporary modification program. B) Records are incomplete. A PORC review was not signed in the required 14 days and the LCR was not included in the closed Temporary Modification package. , STP Response: 1) The PORC review requirement was included in revision 5 of Station Procedure OPGP03-ZO-0003,'" Temporary Modifications", (effective 5/8/87). Temporary modifications initiated prior to that date are not required to have a PORC review. Temporary modifications written per revision 5 or 6 (6 is the current revision)- of ., OPG03-20-0003 have had or will have the required 14 day ) PORC review. There was one exception as identified in item A. 2) A review of temporary modifications was performed on 4/1/87. Temporary modifications that were not closed pricr to that date have been reviewed for completion of LCRs. There was one exception as identified in item A. Those temporary modifications that closed prior to 4/1/87 have been restored. Since the systems are now in the original configuration, there is no reason to review the closed documents. L4/NRC/el/im-1 l J
. _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ - .. .,. i ' . Attachment 1 ST-HL-AE-2291 I File No.: G3.12 Page 2 of 2 C) Performance of LCRs for Procedure = =nd Design Changes STP Response: Procedures were written specifically for use following receipt of an Operating License (OL) and were. evaluated for license compliance on that basis. The Biennial Review Program and each procedure revision includes a re-evaluation of license compliance (reviewing procedure against the current FSAR and Technical Specifications). , In addition, surveillance procedures have been reviewed ] against the Final Draft Technical Specifications. j The following documents are in place to ensure LCRs are performed as required during the design change process: OEP 3.14Q " Review of Design Changes During Document Turnover"; IP 3.1Q " Modifications"; IP 3.20Q "10CFR50.59
' Evaluation". ! 1 L4/NRC/el/im-1 )
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