ML20234A805

Notice of Deviation from Insp on 870413-0515

ML20234A805
Person / Time
Site:	South Texas
Issue date:	06/25/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20234A794	List: ML20234A791 ML20234A805 ML20234A819
References
50-498-87-26, NUDOCS 8707020060
Download: ML20234A805 (2)

Text

,

APPENDIX A NOTICE OF DEVIATION Houston Lighting and Power Company (HL&P) Docket: 50-498 South Texas Project, Unit 1 (STP) Permit: CPPR-128 l

Based on the results of an NRC inspection conducted on April 13 through May 15, 1987', deviations from your commitments were identified. The deviations consisted of failure to establish an index prior to the receipt of records, j inadequate control of records in a temporary working file, and failure to conduct performance testing following plant modifications. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1987), the deviations are listed below:

A. Failure to Establish a Record Index Prior to Record Receipt and Inadequate Control of Records in a Temporary Working File l In Table 3.12-1 of the STP Final Safety Analysis-Report (FSAR), HL&P states conformance to Regulatory Guide (RG) 1.88, Revision 2. RG 1.88 i endorses ANSI N45.2.9-1974, which states, in part. in Paragraph 3.2.2, "The quality assurance records shall be listed in an index . . . . The index should be established prior to receipt of the records . . . ." The STP Document Type List (DTL) is the index maintained by HL&P for STP- J records. Also, ANSI N45.2.9-1974, states in Paragraph 4.3, "The  ;

designated authority shall be responsible for organizing and implementing i a system of receipt control of quality assurance records. This system shall apply to the receipt of records into a temporary working . file and l the permanent. storage file. As a minimum, a receipt control system shall include:

1. A records check list designating the required quality assurance- i records,

2. A record of quality assurance records received, and'

3. Procedures for receipt and inspection of incoming records.

In deviation from the above, expected quality assurance records had not been listed on the DTL prior to receipt by the operations document control center (0DCC). For example, water chemistry analysis ' records and -

radiation and contamination survey reports were-not listed in the DTL-(498/8726-04). Also, an adequate quality. assurance record' receipt control system had not been established as illustrated by the.following examples:-

Daily Reactor Operator log sheets-for the period February through April 1987.were filed loosely in nonfire-rated cabinets erator The Unit Supervisor,

[ including Reactor Yard, Mechanical Operator, Electrical and Reactor Auxiliary Plant Op(MEAB), and

~ Building.

TurbineGeneratorBuilding(TGB)] Logbooks (hardboundlogscovering--

$a g,96,4 Q Og @CK 0 0500049g_

PDR  ;

3

period from 1985 through 1986) were stacked without protection or control on top of the cabinets holding the daily benchboard log sheets. ,

i The Unit Supervisor and Reactor Operator hardbound logbooks for the l periods before those mentioned above could not be located in Nuclear  !

Plant Operations Division (NP00) or ODCC record storage. i l

Seven record transmittals for all Reactor Operations Division records ]

have been executed and were available for audit. Most NP0D l documents, required to be retained as quality records, are not i forwarded to 0DCC by transmittal, thus no accountability for record '

location exists (498/8726-06).

Failure to Conduct Performance Testing Following Plant Modifications

~

B.

In Table 3.12-1.of the STP FSAR, HL&P states conformance to RG 1.33, Revision 2. RG 1.33 endorses ANSI N18.7-1976, which states, in part, in  !

Section 5.2.7, "A suitable level of confidence in structures, systems, or components on which maintenance or modifications have been performed shall be attained by appropriate inspection and performance testing. . . ."

In deviation from the above, the licensee could supply no evidence that performance testing was being performed following installation or removal of temporary modifications (498/8726-10).

Houston Lighting and Power Company is hereby requested to submit to this office, within 30 days of the date of this letter transmitting this Notice, a j written statement or explanation in reply, including for each deviation: l (1) the reason for the deviations 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 time. ,

Dated at Arlington, Texas this /$M day of 1987 i

j J