IR 05000498/1986033

Ack Receipt of 870305 Ltr Informing NRC of Steps Taken to Correct Deviations Noted in Insp Rept 50-498/86-33

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)

Text

{{#Wiki_filter:c ; .- , 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 maintaine

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 bcc to DMB (IE01) bec distrib. by RIV: RPB DRSP RRI-0PS R. D. Martin, RA RRI-CONS Section Chief (RPB/C) RIV File D. Weiss, RM/ALF RSTS Operator R. Pirfo, ELD R. G. Taylor, RPB/C RSB R&SPB Project Inspector R. Hall MIS System

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March 5, 1987 ST-HL-AE-1945 File N 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 l (" ~ ~ - - - - ' 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 10CFR2.20 If you should have any questions on this matter, please contact M S. M. Head at (512) 972-839 '
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J. H. Goldberg

Group Vice President, Nuclear SDP/hg Attachments: Response to Notice of Deviation (498/8633-01)

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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

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, L Street, 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 N G2.4, Y17

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      (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 testin 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 HF These supporting documents had not been made available to the NRC staff on January 2,198 The HFT was scheduled to begin in January 198 (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 tim 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 Procedur It was not our intent to make the modified operating

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Attichm2nt ST-HL-AE-1945 File N G2.4, Y17

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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 HF The five HFT support Preoperational Procedures mentioned in the Notice of Deviation were submitted late primarily because of late data inpu 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 HF 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 comment Unit 2 procedures, including the incorporation of Test Change Notices, will be prepared directly from the Unit 1 preoperational procedure 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 loa L4/NRC/nd/hg-0

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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 complete t , L4/NRC/nd/hg-0 _ _ _ _ _ }}