ML20246K506
| ML20246K506 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/10/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8905180082 | |
| Download: ML20246K506 (3) | |
See also: IR 05000498/1988068
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ley I O 1989
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. In Reply Refer To:
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. Dockets: 50-498/88-68
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50-499/88-68
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Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
o
President, Nuclear
P.O. Box 1700
Houston, Texas 77001
Gentlemen:
Thank you for your letters (ST-HL-AE-2976 and ST-HL-AE-2977) dated February 14,
1989, in response to our letter and the attached Notice of Violation dated
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January 9, 1989. As a result of our review, we found that additional information
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was needed to address several concerns.. During a telephone call on April 20,
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1989, with Mr. R. Ferguson of your staff, we discussed our concerns and the
HL&P position regarding these issues. We understand the additional information
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provided by the telephone discussion to be as delineated below.
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Our first: concern regarded your response to Open Item 498/8868-01.
In this
response you address the " comprehensive enhancement program" that will be
. implemented to upgrade the STP emergency operating procedures.
The res
didnot,however,addresshowtheemergencyoperatingprocedures(EOPs)ponse
would
be maintained following the upgrade.
It is our understanding that specific
,
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responsibilities will be assigned to maintain the E0Ps; this will be based on
your experience and that of industry in the use of E0Ps.
Our second concern regarded your comments on page 3 of 3 in Attachment 2 to
ST-HL-AE-2977. You noted in your comments that in response to Open
Item 498/8708-61, you had committed to complete the documentation.of the many
deviations between your EOFs and the Westinghouse Owners Group Emergency
Guidelines prior to the first refueling outage for Unit 1.
This comitment was
made in your letter dated June 22, 1987. This was prior to your fuel load for
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Unit 1, when you were projecting the first refueling outage for Unit 1 in late
1988. The~ refueling outage was subsequently slipped because of the hardware
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problems'you experienced in the first cycle. The factors that led to the
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refueling outage slippage should not have impacted your E0P upgrade efforts,
and we were concerned that insufficient progress had been made in this area at
the time of this inspection, (October 17 through November 4, 1988).
It is our
understanding that for future programmatic comitments, which are not dependent
on plant status, you will provide a commitment date rather than a plant condition
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such as refueling outage, etc.
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'8905180082 '89051E '
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ADOCK 05000498
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Houston Lighting & Power Company
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If our understanding of your positions, as stated above, is correct no further
response is required and we will review the implementation of your corrective
actions during a future inspection.
If our understanding is not accurate,
please provide the additional information within 30 days of the date of this
letter.
Sincerely,
Original g)gned By
L.1. Callaa
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L. J. Callan. Director
Division of Reactor Projects
cc:
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Houston Lighting & Power Company
ATTN:
M. A. McBurnett, 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 289
Wadsworth, Texas 77483
Houston Lighting & Power Company
ATTN:
J. T. Westermeier, General Manager
South Texas Project
P.O. Box 289
Wadsworth Texas 77483
Central Power & Light Company
ATTN:
R. L. Range /R. P. Verret
P.O. Box 2121
Corpus Christi, Texas 78403
City of Austin Electric Utility
ATTH:
.R. J. Miner,. Chief Operating
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Officer
721 Barton Springs Road
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Newman.& Holtzinger, P.C.
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ATTN:
J. R. Newman,. Esquire
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-1615 L Street, N.W.
- Washington, D.C. _20036
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Houston Lighting & Power Company.
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ATTN:
S. L. Rosen
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P.O. Box 289.'
4
Wadsworth,: Texas 77483
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- Houston Lighting & Power Company
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ATTN:
R. W,-Chewning, Chairman
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Nuclear _ Safety Review Board
P.O. Box 289-
Wadsworth, Texas- 77483
. City Public Service Board
ATTN:
R.'J. Costello/M. T. Hardt
P.O. Box 1771
San Antonio, Texas 78296
Houston Lighting'& Power Company
ATTN: Licensing Representative
Suite 610
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Three Metro Center
Bethesda, Maryland ' 20814 -
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Texas Radiation Control Program Director
bec w/ enclosure:
bec to DMB (IE01)
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Section Chief (DRP/D)
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RPB-DRSS
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RIV File
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R. Bachmenn,.0GC
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RSTS Operator
- G. Dick, NRR Project Manager (MS:. 13-D-18)
ProjectEngineer(DRP/D)
R. D. Martin
G. Sanborn
J. E. Gagliardo
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The Light
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P.O. Box 1700 Houston Texas 77001 (713) 228 9211
Houston Lighting & Power - .
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February' 24,.1989
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ST-HL-AE-2976
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File No.:
G2.4
- j;I FEB 2 31989
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Attention: Document Control Desk
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U. S. Nuclear Regulatory Commission
Washington, DC 20555
South Texas Project Electric Generating Station
Unit 1
Docket No. STN 50-498
Response to NRC Open Items from Inspection 88-68
As requested by your letter dated January 9, 1989, please find attached,
Houston Lighting & Power Company's planned actions to address the issues
identified by the Emergency Operating Procedure Inspection Team.
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An extension to February 14, 1989 for submittal of this response was
granted by Mr. E. Holler, Region IV on Februsry 7, 1989.
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If you should have any questions on this matter, please contact
Mr. M. A. McBurnett at (512) 972-8530.
Q
G. E. Vaughn
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Vice President
Nuclear Operations
GEV/RAF/n1
Attachment:
Response to NRC Open Items from
Inspection 88-68
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NL.89.030.02
A Subddiary of Houston Industries Incorporated
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Houston lj hting & Power Company
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ST-HL-AE-2976
File No.: G2.4-
Page 2
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cc:
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Regional Administrator, Region IV
Rufus S. Scott
Nuclear Regulatory Commis'sion
Associate General Counsel
611 Ryan Plaza Drive, Suite.1000
Arlington, TX 76011 .
Houston Lighting & Power Company
P.
O'. Box 1700
Houston, TX 77001
George Dick, Project Manager
U. S. Nuclear Regulatory Commission
Washington,.DC 20555
Records Center
,
1100 circle 75 Parkway
' Jack E. Bess
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Atlanta, Ga.' 30339-3064
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Senior Resident Inspector-Unit 1
c/o U. S. Nuclear Regulatory Commission
Dr. Joseph H. Hendric
P. O. Box 910
50 Be11 port Lane
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Bay City, TX 77414
Be11 port, NY 11713
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J. I. Tapia
Senior Resident Inspector-Unit 2
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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
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R. L. Range /R. P. Verret
Cent al Power & lie t Company
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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. Costello/M. T. Hardt
City Public Service Board
P. O. Box 1771
San Antonio, TX 78296
Revised 12/21/88
NL.DIST
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Houston Lighting & Power Company
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Attachment
ST-HL-AE-2976
Page 1 of 3
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South Texas Project Electric Generating Station
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Unit 1
Docket No. STN 50-498
Response to NRC Open Items from Inspection 88-68
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. OPEN ITEM 8868-01
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Description
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During the desktop review inconsistencies were identified in the
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following areas:
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EOP administrative procedures and NUREG-0899
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b.
E0P Writers Guide and the'EOPs
c.
EOP Setpoint Document and the E0Ps
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d.
Incorporation of Revision IA of the ERGS
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Response-
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HL&P has developed a comprehensive enhancement program to upgrade the
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quality of the South Texas Project Emergency Operating Procedures (EOPs)
by August 31, 1990.
The principal elements of this program are:
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1.
The evaluation and revision of the administrative control procedures
for writing, verifying, validating, and implementing E0Ps.
This
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will include the incorporation of the guidance of NUREG-0899 and
appropriate comments and recommendations of the NRC EOP inspection
team.
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2.
The establishment of a team of five (5) dedicated individuals
familiar with Westinghouse Pressurized Water Reactors, to conduct the
enhancement program.
(Note: There will be a six week period when
only two will be available because of training commitments. Upon
completion of this training the group will return to full strength).
3.
The revision of Unit I and Unit 2 EOPs to conform to the new
administrative requirements and to incorporate Revision IA of the
ERGS, approved changes to the Setpuint Document, and appropriate
comments / recommendations of the NRC EOP inspection team.
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NL.89.030.02
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Houston Lighting & Power Company
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Attachment
ST-HL-AE-2976
Page 2 of 3
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OPEN ITEM 8868-03
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Description
The review of verification and validation records revealed incomplete and
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missing documentation.
Response
HL&P is taking the following actions to address this issue.
1.
The administrative control procedures associated with E0Ps are being
revised to better conform to the requirements of NUREG-0899.
2.
EOPs will be revised to meet revised EOP Writers Guide requirements.
3.
Each EOP will also undergo full verification and validation prior to
implementation.
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4.
Associat ed verifi. cation and validation documentation will be
maintain,d by the Plant Operations Department until the procedures
are approved for use.
The documentation will then be forwarded, with
the procedure, to the records center for retention.
5.
There will be no attempt to locate or reproduce previous
documentation.
Since revised EOPs will be issued as a group, the
documentation developed during this effort will serve as the new
baseline.
The verification and validation documentation will be
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available for review by August 31, 1990.
OPEN ITEM 8868-04
Description
Procedure IPOP05-EO-EC00, Loss of All AC Power, contained an Immediate
Action step that required a containment entry to isolate letdown in the
event that isolation could not be achieved from the Main Control Board.
Considering the time required to make a containment entry, the action is
not appropriate as an immediate Action step.
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NL.89.030.02
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Attachment
ST-HL-AE-2976
Page 3 of 3
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Response
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The procedures for both Unit 1 and Unit 2 have been revised to delete the
containment entry requirement. Isolation of letdown is now accomplished
by closing the outside containment isolation valve.
OPEN ITEM 8868-05
Description
During the walkdowns several areas were identified that appeared to have
inadequate emergency lighting to allow safe performance of E0P required
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activities. No specific emergency lighting study had been conducted
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relating to E0P usability.
Response
As part of the EOP enhancement program, walkdowns are being performed
which will include checking emergency lighting levels in those areas that
require local EOP action during events which may limit normal lighting
levels. As an interim measure, Plant operations on-shift personnel have
been directed to carry flashlights.
OPEN ITEM 8868-06
Description
There has been no specific general area study performed to determine the
expected post accident environmental conditions (i.e., radiation and
temperature) in those areas that an operator auld be expected to perform
activities required by the EOPs.
Response
Plant Operations has conducted in-plant walkdowns to identify the
location of equipment requiring local operation by the E0Ps. This
information will be used in conjunction with the results of a sample
study of selected areas, scheduled for completion by March 31, 1989, to'
determine what other actions, if any, are necessary.
NL.89.030.02
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