ML20151V920

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/98-06 & 50-499/98-06 Re Failure to Properly Implement Fire Brigade Drills

ML20151V920
Person / Time
Site:	South Texas
Issue date:	08/31/1998
From:	Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
50-498-98-06, 50-498-98-6, 50-499-98-06, 50-499-98-6, NUDOCS 9809150104
Download: ML20151V920 (4)

See also: IR 05000498/1998006

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William T. Cottle, President and

Chief Executive Officer

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, Texas 77483 ]

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SUBJECT: NRC INSPECTION REPORT 50-498/98-06; 50-499/98-06

Dear Mr. Cottle:

Thank you for your letter of August 6,1998, in response to our July 8,1998, letter and

Notice of Violation concerning the failure to properly implement fire brigade drills. We have

reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. 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.

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Sincere!

os eh . Tapia, ief

Project Branch A

Division of Reactor Projects

Docket Nos.: 50-498 i

50-499

License Nos.: NPF-76

NPF-80

cc:

Lawrence E. Martin, Vice President

Nuclear Assurance & Licensing

4 STP Nuclear Operating Company

P.O. Box 289

Wadsworth, Texas 77483

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STP Nuclear Operating Company -2-

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A. Ramirez/C. M. Canady

City of Austin

Electric Utility Department

721 Barton Springs Road 1

Austin, Texas 78704

Mr. M. T. Hardt/Mr. W. C. Gunst

City Public Service Board

P.O. Box 1771

San Antonio, Texas 78296

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D. G. Tees /R. L. Balcom i

Houston Lighting & Power Company

P.O. Box 1700

Houston, Texas 77251

Jon C. Wood

Matthews & Branscomb

One Alamo Center

106 S. St. Mary's Street, Suite 700

San Antonio, Texas 78205-3692

Jack R. Newman, Esq.

Morgan, Lewis & Bockius 1

1800 M. Street, N.W.

Washington, D.C. 20036-5869

Mr. G. E. Vaughn/Mr. C. A. Johnson

Central Power & Light Company ,

P.O. Box 289  !

Mail Code: N5012 j

Wadsworth, Texas 77483

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Records Center

700 Galleria Parkway ,

Atlanta, Georgia 30339-5957

Bureau of Radiation Control

State of Texas I

1100 West 49th Street

Austin, Texas 78756

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STP Nuclear Operating Company -3-

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Mr. Jim Calloway

l Texas Public Utility Commission

William B. Travis Building

1701 North Congress Avenue

P.O. Box 13326

Austin, Texas 78701-3326

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John Howard, Director

Environmental and Natural Resources Policy

Office of the Governor ,

P.O. Box 12428 I

Austin, Texas 78711

Judge, Matagorda County

Matagorda County Courthouse

1700 Seventh Street

Bay City, Texas 77414

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August 6,1998

NOC-AE-000246

File No.: G02.04.02

10CFR2.201

STI: 30680536

U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington,DC 20555

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South Texas Project

Units 1 and 2

Docket Nos. STN 50-498; STN 50-499

Reply to Notice of Violation 9806-02

South Texas Project has reviewed the Notice of Violation contained in inspection report 50-

498; 499/98-06 dated July 8,1998, and submits the attached reply. The only commitments contained

in this correspondence are located in the Corrective Actions section of the attachment.

If there are any questions regarding these replies, please contact Mr. W. E. Mookhoek at

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(512) 972-7274 or me at (512) 972-8757.

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J. J. Sheppard

Vice President, Business Systems

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Attachments: Reply to Notice of Violation 9806-02

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NOC-AE-000246

File No.: G02.04.02

Page 2

Ellis W. Merschoff Jon C. Wood

Regional Administrator,RegionIV Matthews & Branscomb

U. S. Nuclear Regulatory Commission One Alamo Center

611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700

Arlington, TX 76011-8064 San Antonio,TX 78205-3692

Thomas W. Alexion Institute of Nuclear Power

Project Manager, Mail Code 13H3 Operations - Records Center

U. S. Nuclear Regulatory Commission 700 Galleria Parkway

Washington, DC 20555-0001 Atlanta, GA 30339-5957

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David P. Loveless Richard A.Ratliff

Sr. Resident Inspector Bureau of Radiation Control

c/o U. S. Nuclear Regulatory Commission Texas Department of Health

P. O. Box 910 1100 West 49th Street

Bay City,TX 77404-0910 Austin, TX 78756-3189

J. R. Newman, Esquire D. G. Tees /R. L. Balcom

Morgan, Lewis & Bockius Houston Lighting & Power Co.

I800 M. Street, N.W. P. O. Box 1700 +

Washington, DC 20036-5869 Houston,TX 77251

M. T. Hardt/W. C. Gunst Central Power and Light Company

City Public Service ATrN: G. E. Vaughn/C. A. Johnson

P. O. Box 1771 P. O. Box 289, Mail Code: N5012

San Antonio,TX 78296 Wadsworth,TX 77483

A. Ramirez/C. M. Canady U. S. Nuclear Regulatory Commission

City of Austin Attention: Document Control Desk

Electric Utility Department Washington, D.C. 20555-0001

721 Barton Springs Road

Austin,TX 78704

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Attachment

NOC-AE-000246

Page 1 of 2

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Reply to Notice of Violation 9806-02

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1. Statement of Violation:

During an NRC inspection conducted on May 3 through June 13,1998, one violation of NRC

requirements was identified. In accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR Part 50, Appendix R, Section III.I.3.e(2) requires in part that, " Fire brigade training

drills shall as a minimum include..... Assessment of each brigade member's knowledge of his

or her role in the fire fighting strategy for the area assumed to contain the fire."

Contrary to the above, on January 6,1998, a fire brigade training drill did not assess each

brigade member's knowledge of his or her role in the fire fighting strategy for the area

assumed to contain the fire, in that, three individuals arrived at the drill scene within 2

minutes of the drill being terminated and several others did not actively participate in the drill. ,

Additionally, Plant General Procedure OPGPO3-ZF-0002, Revision 3, " Fire Brigade Drills," l

permitted some of the required minimum objectives to not be included in the drill.

This is a Severity Level IV violation (Supplement 1) (499/98006-02).

II. South Texas Project Position:

South Texas Project concurs that the violation occurred.

III. Reason for the Violation:

A less than adequate review resulted in the failure to include all of the requirements of 10CFR50,

Appendix R,Section III.I.3 (Appendix R), in accordance with commitments made in the South

Texas Project Fire Hazards Analysis Report (FHAR), during the preparation of the current revision

to the plant procedure governing Fire Brigade drills. Had a thorough review of the FHAR been

completed, the requirements included in Appendix R would have been identified , incorporated into

the plant procedure, and been incorporated into the Fire Brigade drill conducted on January 6,1998.

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Contributing causes of the event include a lack of self assessments of the conduct of Fire Brigade

l drills, less than adequate monitoring of the implementation of Fire Brigade drills by Fire Protection

l Program management personnel, and a lack of familiarity and understanding of regulatory

! requirements by the Fire Protection Program staff.

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Attachment

NOC-AE-000246

Page 2 of 2

IV. Corrective Actions:

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1. The plant procedure that governs Fire Brigade drills has been revised to incorporate all the

requirements of 10CFR50, Appendix R, Section 111.1.3,in accordance with commitments

made in the South Texas Project Fire Hazards Analysis Report.

2. Credit for the Fire Brigade drill conducted on January 6,1998 has been removed for all

participants.

3. An evaluation was conducted that confumed Fire Brigade members met the requirunents for

attending Fire Brigade drills.

4. The plant procedure that governs Fire Brigade drills has been revised to clearly identify

requirements for Fire Brigade members to receive credit for participation in Fire Brigade

drills,

i 5. The plant procedure that governs Fire Brigade drills has been revised to establish the

minimum number of drill evaluators required to effectively assess drill objectives.

6. The plant procedure that governs Fire Brigade drills has been revised to include a

requirement for management oversight of the implementation of the procedure.

7. The plant procedure that governs Fire Brigade drills has been revised to require an annual self

assessment by the Fire Protection Coordinator.

8. Fire Protection Program Procedures will be reviewed, and procedures revised as required, to

insure the current licensing commitments are properly reflected by January 28,1999.

9. Training will be provided to the Fire Protection staff on the licensing commitments applicable

to program implementation. This willinclude upgrading the technical knowledge of

individuals involved in the Fire Protection Program. This action will be completed by January

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28,1999.

l V. Date of Full Compliance:

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South Texas Project is in full compliance,

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