ML20236V693
| ML20236V693 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/01/1987 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8712070009 | |
| Download: ML20236V693 (2) | |
See also: IR 05000498/1987041
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In Reply Refer To:
Dockets:
50-498/87-41
50-499/87-41
i 1987
Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P.O. Box 1700
Houston, Texas
77001
I
Gentlemen:
Thank you for your letter of October 16, 1987, in response to our
letter and Notice of Deviation dated September 16, 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,
Origiout signed By.
L. J. Callan
L. J. Callan, Director
Division of Reactor Projects
cc:
Houston Lighting & Power 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
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Houston Lighting & Power Company
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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
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City of Austin
ATTN:
M. B. Lee /J. E. Malaski
P.O. Box 1088
78767-8814
Texas Radiation Control Program Director
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- RIV File
- Lisa Shea, RM/ALF
- RSTS Operator
R. Bachmann, OGC
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Kadambi, NRR Project Manager
- R. Taylor
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October 16, 1987
ST-HL-AE-2383
File No.: G2.4
U. S. Nuclear Regulatory Commission
Attention:
Document Control Desk
20555
South Texas Project Electric Generating Station
Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
Response to Notice of Deviation
Reference (1) NRC Inspection Report 87-41 dated September 17, 1987
(ST-AE-HL-91382).
Pursuant to your request stated in reference 1 please find our response
to Notice of Deviation 8741-01.
If you should have any questions on this matter, please contact Mr.
S. M. Head at (512) 972-8392.
c1uf
G. E. Vaughn
Vice President,
Nuclear Plant Operations
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Attachment:
Response to Notice of Deviation
498/8741-01 and 499/8741-01
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Octobtr 16, 1987
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ST-HL AE-2383
Houston Lighting & Power Company
File No.: G2.4
Page 2
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cc:
Regional Administrator, Region IV
Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, IX 76011
N. Prasad Radambi, Proj ect Manager
U. S. Nuclear Regulatory Commission
7920 Norfolk Avenue
Bethesda, MD 20814
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 / Operations
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
M. B. Lee /J. E. Malaski
City of Austin
P. O. Box 1088
Austin, TX 78767-8814
R. J. Costello/M. T. Hardt
City Public Service Board
P. O. Box 1771
San Antonio, TX 78296
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Attachment
ST-HL-AE-2383
File . G2.4
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Page 1 of 2
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Response to Notice of Deviation
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498/8741-01 and 499/8741-01
I. Statement of Deviation
Based on the results of an NRC inspection conducted on June 15 through
July 2, 1987, a deviation of your Final Safety Analysis Report (FSAR) was
identified.
The deviation consisted of failure of the maintenance
program to meet the FSAR quality requirements.
in accordance with the
"Ceneral Statement of Policy and Procedure for NRC Enforcement Actions,"
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10 CFR Part 2, Appendix C (1987), the deviation is listed below:
Section 3.2 of the South Texas Project FSAR, Amendment 61, requires
systems important to safety such as fire protection, radwaste,
post-accident monitoring, qualified display processing, and similar
equipment important to safety systems and components to have quality
'
requirements of 10 CFR 50, Appendix B, or QA requirements of the NRC
branch technical positions imposed on the aforementioned systems.
In deviation from the above, the preventive maintenance (PM) program
and the maintenance work request (MWR) program failed to meet the
FSAR requirements in certain areas.
In particular, some components
identified on equipment lists as Quality Class 9 within the fire
protection system were not treated as quality related in regard to
PMs and MWRs.
(498/8741-01; 499/8741-01)
II. Reason for Deviation
4
The quality classification in section 3.2 of the FSAR was misinterpreted
"
in regards to its applicability to PMs and MWRs. While it was understood
that the subj ect systems were quality related, the scope of review by QA
was determined by the Engineering assigned Quality Classification and not
a blanket coverage of all components within the system.
III. Corrective Steps Taken and Results Achieved
NPOD and Operations QA have reviewed the affected PM's and MWR's which
were not identified as quality related when they were performed.
This
review demonstrated that only 11 MWRs/PMs would have required quality
inspection.
An inspection of these work packages was made with no
discrepancies found.
NPOD Maintenance will revise the affected PMs
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prior to being reissued for performance.
Those PMs not yet issued will
be revised prior to use.
NPOD Maintenance has issued written directions to ensure PMs and MWRs are
not issued for affected components unless they are processed as " quality
related." An interim measute was provided to ensure compliance with the
MWR/FM procedures and the FSAR.
The Preventative Maintenance and the
Maintenance Work Request Programs were revised to clarify the determina-
tion of proper quality classification.
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NPOD Maintenance has provided additional tr(ppiL
S to Maintenance planners
in identifying quality requirements for mair pay../e activities .
IV. Corrective Steps Taken to Prevent Recurrence g
The September 1987 revision of the Preventative Maintenance Program
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Procedure requires the affected PMs to be revised and reviewed by QC
prior to approval for work performance.
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V. Date of Full Compliance
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STP is presently in full compliance.
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