ST-HL-AE-2532, Responds to Deviations Noted in Insp Rept 50-498/87-77. Corrective Actions:Procedure Change Issued to OPOPO3-ZQ-0030, Maint of Plant Operations Logbooks on 871216 Requiring Entries in Reactor Operators Logbook

Responds to Deviations Noted in Insp Rept 50-498/87-77. Corrective Actions:Procedure Change Issued to OPOPO3-ZQ-0030, Maint of Plant Operations Logbooks on 871216 Requiring Entries in Reactor Operators Logbook

ML20147B647
Person / Time
Site:	South Texas
Issue date:	02/26/1988
From:	Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ST-HL-AE-2532, NUDOCS 8803020155
Download: ML20147B647 (9)

Text

. c The Light company P.O. Box 1700 11ouston, Texas 77001 (713) 228 9211 Ifouston Lighting & Power - . - - - - -- - - - - -

February 26, 1988 ST-HL-AE-2532 File No.: G2.04 10CFR Part 2 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Vashington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. 50-498 Response to Deviations Included ir Inspection Report 87-77 HL&P was reviewed the Notice of Deviations included in Inspection Report 87-77 and submits the attached response purs'iant to 10CFR Part 2, Appendix C.

In addition, we have addressed your concerns relative to the Licensing Comment Tracking System in Attachment B. If you have any questions on this subj e c t , please contact S. H. Head at (512) 972-8392.

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G. E. Vaughn Vice President Nuclear Plant Operations GEV/SHH/1s Attachment At Response to Notice of Deviations Included in Inspection Report 87-77 Attachment B Response to NRC Concern Relative to the Adequacy of the HL&P Licensing Ccmnitment Tracking System i

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A Subsidiary of Ilouston Industries incorporated 6 8803020155'8150226

{DR ADOCK 05000498 DCD

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~ llouston 1.ighting & Power Company t

ST-HL-AE-2532-File No.: G2.04 Page 2 cc: I hegional Administrator, Region IV ~ Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 Houston, TX 77001 N. Prasad Kadambi, Project Mansger U. S. Nuclear "agulatory Commission IKPO 1 White Flint North Records Center 11555 Rockville Pike 1100 Circle 75 Parkway Rockville, MD 20859 Atlanta, Ga. 30339-3064 I

Dan R. Carpenter Senior Resident Inspector / Operations .

c/o U. S. Nuclear Regulatory Commission l P. O. Box 910 +

Bay City, TX 77414 I

J. R. Newman, Esquire  ;

Newman & Holtzinger, P.C. i 1615 L Street, N.W. t Washington, DC 20036 jn R. L. Range /R. P. Verret  !

, Central Power & Light Company [

P. O. Box 2121  !

Corpus Christi, TX 78403 j

-I R. John Miner (2 copies) j

- Chief Operating Officer  !

, City of Austin Electric 1:tility

• j 721 Barton Springs Road

• i Austin. TX 78704 .

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i R. J. Costello/M. T. Hardt 3

City Public Service Board i P. O. Box 1771 ,

j San Antonio, TX 78296 1

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Revised 02/03/88 i NL.LER. DISTR.1 r

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Attachment A '

~ Response to Notice of Deviation From Inspection Report 87-77 (Page 1 of 6)

Reference 1) Letter frua J. H. Goldberg to Document Control Desk Dated July 15, 1987 (ST-HL-AE-2298)

Reference 2) Letter from G. E..Vaughn to Document Control Desk Dated December 31, 1987 (ST-HL-AE-2467)

Deviation A.1

• i A.I.I Statement of Deviation l

In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC, the licensee responded to the findings of the operational readiness inspection of June 29 through July 2, 1987, and the observations discussed during the exit interview on July 2, 1987. The following deviation from the commitment stated in the July 15, 1987, letter was identified:

In response to Observation No. 4, the licensee stated that, "WCC activities are currently included in maintenance audit plans."

In deviation from the above, the NRC inspector found on December 15, 1987, that the current maintenance audit plan, "Audit D3, Haintenance Activities," dated July 13, 1987, did not contain provisions for a review of VCC activities, and the operations QA manager stated that he had never intended to audit WCC activities.

A.I.II Reason fer Deviation The intent of HL&P commitment was that quality related maintenance activities that could be affected by the Work Control Center (WCC) are included in the maintenance audit plans. The statement was not intended to imply that Nuclear Assurance would audit the WCC specifically.

As discussed in Reference 2, audits and an assessment have been performed which included within tneir scope the activities of the WCC and the Daily Work Activity Schedule process. We believe that this type of review by Nuclear Assurance fulfills the intent of the commitment made by HL&P in Reference 1, and as such a deviation does not exist.

Since audits of WCC activities have occurred, the statement made by the QA manager was addressing the fact that he did not plan to audit the VCC specifically.

NL.88.049.01

' Attachment A Response to Notice'of Deviation From Inspection Report 87-77 (Page 2.of 6) ,

Deviation A.1 (Cont.)

A.I.III Corrective Actions That Have Been Taken Not applicable 3 A.I.IV Corrective Actions That Will Be Taken Not applicable A.I.V Date When Full Compliance Will Be Achieved

• STPEGS is in full compliance at this time.

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NL.88.049.01

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Attachment A.

Response to Notice of Deviation-From Inspection Report 87-77 (Page 3 of 6) ,

i Deviation A.2 A.2.1. Statement of Deviation ,

l In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC the .

licensee responded to the findings of the~ operational readiness  ;

inspection of June 29 through July 2, 1987, and the observations discussed during the exit interview on July 2, 1987. . The following deviation'from the commitments stated ~in the July 15,.

1987, letter was identified:

1 In response to Observation No. 14, the licensee stated that,- .

"Since the LCO log sheet may not be visible to the other i licensed operators in the control room, HL&P will also '

l require entries,in the unit supervisor and control room logs -

of entry into an LCO and exit from an LCO."

In deviation from the above, Cor. trol Room Procedure OPSP03-ZQ-0001, which had been last revised (Revision 1) on  ;

July 31, 1987, required only that the vrit supervisor log

• record entries of the plant's entry into an LCO and exit from i an LCO. The NRC inspector also found on December 15, 1987, i that the control room log did not contain entries of LCO '

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A.2.II. Reason for Deviation

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The reason for this deviation is that the responsible department i failed to completely implement the commitment.  ;

I 1 A.2.III. Corrective Actions That Have Been Taken  !

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, A procedure change was issued to OPOP03-ZQ-0030'"Haintenance of j l

Plant Operations Logbooks" on December 16 requiring entries in the  ;

l reactor operators logbook (control room log). 'i To address the root cause and generic implications of this  :

deviation, please see Attachment B.

j A.2.IV Corrective Actions To Be Taken i

No additional corrective actions are considered necessary. '

J A.2.V. Date When Full Compliance Will Be Achieved '

i STPEGS is in full compliance at this time.

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Attachment A-Response to Notice of Deviation From Inspection Report 87-77 (Page 4 of 6)

Deviation A.3

1. Statement of Deviation i

In a letter (ST-HL-AE-2298), dated July 15, 1987, to the NRC, the licensee responded to the findings of the operational readiness inspection of June 29 through July 2, 1987, and the observations discussed during the exit interview on July 2, 1987. The following deviation from the commitment stated in the July 15, 1987, letter was identified: i In response to Observation No. 35, the licensee stated that, "A procedure will be written-which specifies actions to be taken as a result of ISEG reports. This procedure will be completed by September 30, 1987. As an interim measure, -

plant management has directed that responses for ISEG reports be generated by responsible managers which address pertinent issues identified in the report."

l In deviation from the above, the NRC inspector found on 1

December 15, 1987, that no response had been generated to an ISEG report entitled, "ISEG Observation of the Work Control Center," and dated September 10, 1987. This' report was issued prior to the issuance of the committed procedure on September 28, 1987.

II. Reason for Deviation ,

As noted In Reference 2, ISEG originally determined that a.

response was not required. A reevaluation determined that the findings of the observation were serious enough to warrant a response.

III. Co.rective Actions Taken The Outage management group provided a response to the ISEG observations on January 20, 1988.

IV. Corrective Actions That Will Be Taken No additional corrective actions are considered necessary.

V. Date When Full Compliance Will Be Achieved STPEGS is in full compliance at this time.

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Attachment A Response to Notice of Deviation.

From Inspection Report 87-77 (Page 5 of 6)

Deviation B I. Statement of Deviation In a letter (ST-HL-AE-2328), dated August 18,-1987, to the NRC, the licensee clarified their response as reported in their July 15, 1987, letter for Obss sstion No. 20. Their revised response stated that for the processing and investigating of anonymous tips related to drug use, the NSD will "contact local law enforcement of ficials concerning the subject of the anonymous tip."

In deviation from the above, an NSD representative stated that local law enforcement officials were contacted only when the allegation had been confirmed or a substantial amount of information was provided by the anonymous alleger.

II. Reason for Deviation This deviation was caused by a breakdown in communications between  ;

the parties involved in establishing the subj ect commitment. The organization that submitted this commitment to the NRC understood i that the local law enforcement would be contacted for all anonymous tips. In fact, the investigating organization treated

anonymous tips as indicated above.

1 III. Corrective Actions Taken HL&P has reevaluated the original commitment made to the NRC and has concluded that it is not appropriate that the local law enforcement be contacted for all anonymous tips. Accordingly, the "STP Drug and Alcohol Screening Behavioral Observation Action Guidelines for Fitness for Duty Program" has been revised to read as follows:

"If the investigator determines that enough specific information has been provided to lend credibility to the referral, the Sheriff's Department or other LLEA ar, i appropriate shall be contacted to request information which l maybe of assistance in the investigation."

In addition, plant management has had ';;aussions with plant personnel to reinforce the concept that camaitments east be accurately communicated to the NRC.

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To address the generic implication of the item, please see Attachment B.

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Attachment A ,

Response to Notice of Deviation From Inspection Report 87-77

. (Page~6 of 6) ,

1 Deviation B (Cont.)

IV. Corrective Actions To Be Taken {

No additional actions on this issue are required.

V. Date When Full Compliance Will Be Achieved STPEGS is in full compliance at this time.

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-t Attachment B Response to NRC Concern Relative to the Adequacy of the HL&P Licensing Commitment Tracking System Subsequent to the submittal of HL&P response to the initial Operational Readiness Inspection findings (provided at the er t; '.he commitments made therein were entered on the Licensing Commitment Tracking System (LCTS). The "status" of the completion of each commitment was monitored by upper management on a weekly basis to ensure timely closure._ A compliance type review was not performed during this time frame to ensure that the scope and intent of the commitments had actually been satisfied as is done for 10CFR50.55e reports and Inspection and Enforcement Bulletins. This review could have revealed that commitments were in fact not complete or that-additional clarifications should be provided to the NRC.

Corrective Action To preclude this situation occurring in the future, the following actions have g been taken.

. The Licensing Group is performing compliance reviews for the closure of ,

commitments made to the NRC via correspondence.

. Plant Management has revised the policy on Licensing Commitments i stressing the need for accurately portraying commitments in correspondence to the NRC and specifying rules whereby commitments can i be changed.

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