ML20246K506

Ack Receipt of 890214 Response to Violations Noted in Insp Repts 50-498/88-68 & 50-499/88-68.Concerns Raised Re Maint of Emergency Operating Procedures After Upgrade & Slippage of Emergency Operating Procedures Upgrade Efforts

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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L ley I O 1989

y . In Reply Refer To:

! . Dockets: 50-498/88-68

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50-499/88-68

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Houston Lighting & Power Company

o ATTN: J. H. Goldberg, Group Vice

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 l

January 9, 1989. As a result of our review, we found that additional information f

was needed to address several concerns.. During a telephone call on April 20, '

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 i

provided by the telephone discussion to be as delineated below. -1

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 i

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 ,

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 ;i

such as refueling outage, etc.

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• RIV:C:0PS *D:DRS D:DRPL  :

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• Previously concurred

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'8905180082 '89051E ' d( ,

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Houston Lighting & Power Company -2-

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: .,

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

l Officer

721 Barton Springs Road

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Austin, Texas 78704

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Newman.& Holtzinger, P.C.

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ATTN: J. R. Newman,. Esquire 1

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-1615 L Street, N.W.

- Washington, D.C. _20036 ,

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Houston Lighting & Power Company. '

ATTN: S. L. Rosen l

P.O. Box 289.' 4

. Wadsworth,: Texas 77483

- Houston Lighting & Power Company 1

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ATTN: R. W,-Chewning, Chairman 1

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 ..

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) DRS

MIS System RPB-DRSS ,

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R. Bachmenn,.0GC .

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

Houston Lighting & Power - . . - . - . . - . . - --

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February' 24,.1989

ST-HL-AE-2976 -

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File No.: G2.4 g[QiI N {$ ' *

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9 FEB 2 31989 t

U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

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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. -

If you should have any questions on this matter, please contact

Mr. M. A. McBurnett at (512) 972-8530.

.

Q

G. E. Vaughn

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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ST-HL-AE-2976

File No.: G2.4-

Page 2 4

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cc: I

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Regional Administrator, Region IV Rufus S. Scott

Nuclear Regulatory Commis'sion Associate General Counsel

611 Ryan Plaza Drive, Suite.1000 Houston Lighting & Power Company

Arlington, TX 76011 . P. O'. Box 1700

Houston, TX 77001

George Dick, Project Manager

U. S. Nuclear Regulatory Commission INPO ,

Washington,.DC 20555 Records Center

1100 circle 75 Parkway

' Jack E. Bess .

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Atlanta, Ga.' 30339-3064

Senior Resident Inspector-Unit 1

c/o U. S. Nuclear Regulatory Commission Dr. Joseph H. Hendric

P. O. Box 910 50 Be11 port Lane -

Bay City, TX 77414 Be11 port, NY 11713

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J. I. Tapia

Senior Resident Inspector-Unit 2 .s  !

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 ht Company

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 ,

Attachment

ST-HL-AE-2976

Page 1 of 3

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South Texas

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Project Electric Generating Station

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

During the desktop review inconsistencies were identified in the .

following areas: ,

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a. EOP administrative procedures and NUREG-0899  :,p

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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 S

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

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for writing, verifying, validating, and implementing E0Ps. This I

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

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

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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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

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inadequate emergency lighting to allow safe performance of E0P required

activities. No specific emergency lighting study had been conducted  %

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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