ML20148H985

Ack Receipt of 880226 Ltr Informing NRC of Steps Taken to Correct Deviations Noted in Insp Repts 50-498/87-77 & 50-499/87-77

ML20148H985
Person / Time
Site:	South Texas
Issue date:	03/22/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8803300135
Download: ML20148H985 (2)

See also: IR 05000498/1987077

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In Reply Refer To:

Dockets: 50-498/87-77

50-499/87-77

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Houston Lighting & Power Company

ATTN: J. H. Goldberg, Group Vice

President, Nuclear

P.O. Box 1700

Houston, Texas 77001

Gentlemen:

Thank you for your letter. of February. 26, 1988, in response to our letter

and Notice-of Deviation dated January 27, 1988. We have reviewed your reply

i and find it responsive to the concerns raised.in our Notice of Deviation. We

l will review the implementation of your corrective actions during a future {

inspection to determine that full compliance has been achieved and will be

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maintained. I

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Sincerely,

Original < Signed IlY

L. I, Callan

L. J. Callan, Director

Division of Reactor Projects

cc:

Houston Lighting & Power Company

ATTN: M. A. McBurnett, Manager i

Operations Support Licensing '

P.O. Box 289 l

Wadsworth, Texas 77483

Houston Lighting & Power Company

ATTN: Girald E. Vaughn, Vice President ,

Nuclear Operations

! P.O. Box 1700

l Houston, Texas 77001 -

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Houston Lighting & Power -2- 'I

Company

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Hcuston Lighting &. Power Company

. ATTN: S.-L. Rosen

P.O. Box 289

Wadsworth, Texas 77483

Central Power & Light Company

' ATTN: R. L. Range /R. P.-Varret

P.O. Box 2121

Corpus Christi, Texas 78403  !

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City Public Service Board

ATTN: R. J. Costello/M. f. Hardt

P.O. Box 1771

San Antonio, Texas 78296

City of Austin Electric Utility

ATTN: R. J. Miner, Chief Operating

Officer

721 Barton Springs Road '

Austin, Texas 78704

Texas Radiation Control Program Director

bcctoDMB(IE01)

bec distrib. by RIV- '

DRP RRI-0PS- J

R. D. Martir., RA DRS

SectionChief(DRP/D) RPSB-DRSS  !

MIS System RIV File l

Lisa Shea, RM/ALF RSTS Operator i

R. Bachmann, 0GC D. Hunnicutt I

P. Kadambi, NRR Project Manager R. Hall

TSS D. Powers

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. The Light

company P.O. Box 1700 Houston. Texas 77001 (713) 228 9211

Houston Light.ing & Power

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February 26, 1988

ST-HL-AE-2532

File No.: G2.04

10CFR Part 2 _m

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U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

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Washington, DC 20555 -

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South Texas Project Electric Generating Statj,on

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Unit 1

Docket No. 50-498

Response to Deviations

Included in Inspection Report 87-77

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HL&P was reviewed the Notice of Deviations ircluded in Inspection

Report 87-77 and submits the attached response pursuant to 10CiR 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. M. Head at (512) 972-8392.

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G. E. Vaughn l

Vice President

Nuclear Plant Operations

GEV/SMH/1s

Attachment A: Response to Nott 3 of Deviations

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Included in Inspi '. ion Report 87-77 f-

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Attachment B: Response to NRC Concern Relative to d>

the Adequacy of the HL&P Licensing h, r

Commitment Tracking Sys tem , d

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NL.BB.049.01

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Houston Lighting & Power Company

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ST-HL-AE-2532 ,

File No.: G2.04  !

Page 2 l

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CCI

'- Regional Administrator, Region IV Rufus S.' Scot *.

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 Manager

U. S. Nuclear Regulatory Commission INPO

1 White Flint North Records Center

11555 Rockville Pike 1100 Circle 75 Parkway

Rockville, MD 20859 Atlanta, Ga. 30339-3064

Dan R. Carpenter

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 , ,

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R. John Miner (2 copies)

Chief Operating Officer

City of Austin Electric Utility  ;

721 Barton Springs Road 1

Austin, TX 78704

R. J. Costello/M. T. Hardt

City Public Service Board

P. O. Box 1771

San Antonio, TX 78296

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Revised 02/03/88

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Attachment A

Response to Notice of Deviation

From Inspection Report 87-77

(Page 1 of 6)

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Reference 1) Letter from 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)

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Deviation A.1

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A.1.I Statement of Deviation

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

licensee responded to the findings of the operational readiness

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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, Maintenance Activities," dated July 13, 1987, did

not contain provisions for a review of WCC activities, and

the operations QA manager stated that he had never intended

to audit WCC activities.

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A.I.II Reason for 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 their scope the activities of the l

WCC and the Daily Work Activity Schedule process. We believe that I

this type of review by Nuclear Assurance fulfills the intent of l

the commitment made by HL&P in Reference 1, and as such a '

deviation does not exist. ,

Since audits of WCC activities haue occurred, the statement made

by the QA manager was addressing the fact that he did not plan to

audit the WCC specifically.

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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 2 of 6)

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Deviation A.1 (Cont.T

A.I.III Corrective Actions That Have Been Taken

Not applicable

A.I.IV Corrective Actions That Will Be Taken

Not applicable -

A.1 V Date When Full Compliance Will Bs Achieved

. STPEGS is in full compliance at this ti$'e.

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Attachment A

Response to Notice of Deviation

From Inspection Report 87-77

(Page 3 of 6)

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Deviation A.2

A.2.I. Statement of Deviation

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

licensee i*esponded 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:

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

. "Since the LCO log sheet may not be visible to the other

licensed operators in the control room, HL&P will also

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, Control Room Procedure

OPSP03-ZQ-0001, which had been last revised (Revision 1) on

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

record entries of the' plant's entry into an LCO and exit from

an LCO. The NRC inspector also found on December 15, 1987,

that the control room log did not contain entries of LCO

status.

A.2.II. Reason for Deviation

Th'e reason for this deviatJon is that the responsible department

failed to' completely implement the commitment.

A.2.III. Corrective Actions That Have Been Taken

A procedure change was issued to OPOP03-ZQ-0030 "Maintenance of

Plant Operations Logbooks" on December 16 requiring entries in the

reactor operators logbook (control room log).

To address the root cause'and generic implications of this

deviation, please see Attachment B.

A.2.IV Corrective Actions To Be.Taken

No additional corrective actions are considered necessary. ,

A.2 V. Date When Full Compliance Will Be Achiev'ed

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 ,

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' From Inspection Report 87-77

(Page 4 of 6)

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Deviation A.3

I. Statement of Deviation

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:

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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

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issues identified in the report."

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

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 com.aitted procedure on September

28, 1987.

II. Reason for Deviation

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l As noted in Reference 2 ISEG originally determined that a

response was not required. A reevaluation determined that the

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findings of the observation were serious enough to warrant a

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III. Corrective Actions Taken

The Outage management group provided a response to the ISEG

observations on January 20, 1988.

IV. Corrective Actions That Vill Be Taken

No additional corrective actions are considered necessary.

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V. Date When Full Compliance Vill Be Achieved

3TPEGS is in full compliance at this time. l

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, Attachment A

Response to Notice of Deviation

From Inspection Report 87-77

(Page 5 of 6)

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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 Observation 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 Deviatien

This deviation was caused by a breakdown in communications between

the parties involved in establishing the subject commitment. The

organization that submitted this commitment to toe NRC understood

that the local law enforcement would be contacted for all

anonymous tips. In fact, the investigating organization treated

anonymous tips as indicated above.

III. Corrective Actions Taken

, HL&P has reevaluat9d the original commitment made to the NRC and

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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 1

Guidelines for Fitness for Duty Program" has been revised to read '

as follows:

"If the investigator determines that enough specific

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information has been provided to lend credibility to the

referral, the Sheriff's Department or other LLEA as

appropriate shall be contacted to request information which

maybe of assistance in the investigation."

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In addition, plant management has had discussions with plant

personnel to reinforce the concept that commitments must be ,

accurately communicated to the NRC.

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l To address the generic implication of the item, please see

Attachment B.

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Attachment B

Response to NRC Concern Relative to

the Adequacy of the KL&P Licensing ,

Commitment Tracking System ,

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.. Subsequent.to the. submittal of HL&P response to the initial Operational

Readiness Inspection findings (provided at the exit) the 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

10CFR50.5!e reports and Inspection and En,forcement Bulletins. This review

could have revealed thct commitments were in fact not complete or that ,

additional clarifications should be provided to the NRC.

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Corrective Action r

"To preclude this situation occurring in the future, the following actions have -

been taken,

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

commitments made to the NRC via correspondence.

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. Plant Management has revised the policy on Licensing Commitments  !

stressing the need for accurately portraying commitme ts in

correspondence to the NRC and specifying rules whereby commitments can

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Attachment A

Response to Notice of Deviation

From Inspection Report 87-77

(Page 6 of 6)

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IV. Corrective Actions To Be Taken

i No additional actions on this issue'are required.

V. Date When Full Compliance Will Be Achieved

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STPEGS is in full compliancesat this time. ,

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