ML20149F557

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in 871216 Notice of Violation

ML20149F557
Person / Time
Site:	South Texas
Issue date:	02/09/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8802170253
Download: ML20149F557 (2)

Text

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.I'n Reply Refer To:

Dockets: 50-498/87-64 FEB 9M '

50-499/87-64 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 January 15. 1988, in response to our letter and Notice of Violation dated December 16, 1987. 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 detemine that full compliance has been achieved and will be m&intained.

Sincerely.

Original Signed By, A. B. Beach l L. J. Callan Director Division of Reactor Projects CC:

Houston Lighting & Power Company ATTN: M. Wisenberg, Ma.1ager Nuclear Licensing P.O. Box 1700 Houston, Texas 77001 Houston Lignting & Power Company ATTN: Gerald E. Vaughn, Vice President Nucitear Operations P.O. Box 1700 Houston, Texas 77001 8802170253 800209 l PDR ADOCK 05000490 0 PDR

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Central Power & Light' r.ompany ATTN: R. L. Range /R. P. Verret

'P.O.. Box 2121 l Corpus Christi. Texas 78403 City-Public Service Board ATTN: R. J. Costello/M. T. Hardt LP.O. Box-1771-

-San Antonio, Texas 78296' City of Austin ~

ATTN: M. B. Lee /J. E.: Malaski P.O. Box 1088

-Austin, Texas- 78767-8814  ;

Texas Radiation Control Program Director bectoDMB(IE01) bec distrib. by RIV:

• DRP *RRI-0PS R. D. Martin RA *RRI-CONST.

• SectionChief(DRP/0) RPSB-DRSS

• MIS System *RIV File Lisa Shea, RM/ALF *RSTS Operator R. Bachmann 0GC *H. Bundy

• P. Kadambi, NRR Project Manager *R. Taylor

• TSS *R. Hall

• DRS D. Powers l-I

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'l 3 l The Light com n P.O. Box 1700 Houston. Texas 77001 (713) 228 9211 Ilouston Lighting k Power s

January 15, 1988 ST-HL-AE-2477 File No.: G2.4 f h@{g--

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10CFR2.201 bl- d

-_.-j U. S. Nuclear Regulatory Commission  ;

Attention: Decument Control Desk ' l Washington, DC 20555 i South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Response to Notice of Violation 8764-01 Houston Lighting & Power Company has reviewed Noticu of Violation 8764-01 dated December 16, 1987 and submits the attached response pursuant to 10CFR 2.201.

If you should have any questions on this matter, please contact Mr. S.M. Head at (512) 972-8392.

• "f G. E. Vaughn Vice President Nuclear Plant Operations GEV/SMH/12s Attach.nent: Response to Notice of Violation 8764-01 I

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<S ST-HL-AE-2477 File No.: G2.4 Page 2 cc:

Regional Administrator, Region IV Nuclear Regulatory Commission  !

4 611 Ryan Plaza Drive, Suite.1000 Arlington, TX 76011

+ N. Prasad Kadambi Project Manager U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Dan R. Carpenter Senior Resident Inspector / Operations c/o U. S. Nuclear Regulatory Commission P. O. Box 910 Bay city, TX 77414 J. K. Newman, Esquire Newman & Holtzinger, P.C.

1615 L Street, N.V.

Washington, DC 20036 R. L. Range /R. P. Verret Centre.1 Power & Light 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 1

R. J. Costello/M. T. Hardt City Public Service Board P. O. Box 1771

, San Antonio, TX 78296 Rufus S. Scott Associate General Counsel  !

Houston Likhting & Power Company P. O. Box 1700 ,

Houston, TX 77001  !

Revised 11/20/87 t

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Attachment ST-HL-AE-2477 File No.: G2.4 Page 1 of 3 South Texas Project Electric Generating Ststion Unit 1 Docket No. STN 50-498 Response to Notice of Violation (499/276pJ,Q I. Statement _of Violation Failure To Follow The Anoroved Procedure For Performine Plant Operation South Texas Project Electric Generating Station (STPEGS) Technical Specifications (TS), Section 6.0 (Administrative Controls), Specification 6.8.1.a requires that written procedures shall be established, implemented, and maintained for plant operations. Plant Procedure OPGP03-EO-0004 implements the requirements of this TS.

Contrary to the above, a chemical operations boric acid mixing activity was observed by the NRC inspector in which the chemical operato*/ was not following the procedure (1PCP13-PT-DOOl) as written, in that he was not performing all procedural steps. Additionally, the boric acid mixing procedure requires verification that the boric acid batching valve lineup checklist is in effect prior to. mixing operations. No objective evidence was available that this lineup checklist had been performed and was in effect.

II. Reason for Violation Since boric acid batching is a routine evolution involving relatively simple operator tasks, plant procedures do not require that operators have a copy of the procedure (IPCP13-PF-0001) in their possession while the evolution is in progress. Operators are responsible for performing steps in sequence as written in the procedure even though a copy is not present. At the time of the violation, although an approved procedure l was present, the operator was not verifying every step against the procedure. Due to inattentiveness on the part of the assigned operator l and lack of complete understanding of the requirements of procedural compliance, two steps were not performed.

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A review of the Records Management System indicated that the most recent boric acid batching lineup check list had been forwarded to the I

Operations Document Control Center (ODCC). This check list was not in the Chemical Operations system status file and hence, contrary to procedural requirement, the checklist was not physically verified by the operator. Due to a lack of understanding of the need for objective evidence to verify lineup ststus, th1 procedural requirement to verify the boric acid batching lineup checklist was not satisfied.

NL. RESP. NOTICE

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.Q,t 8 Attachment ST-HL-AE-2477 File No.: G2.4 Page 2 of 3 III. Corrective Action Taken and Results Achieved HL&P has taken or will take the following actions to correct the conditious resulting in the violation:

1. The chemical operater was immediately relieved.

2. The chemical operator involved was verbally counselled concerning the requirements to follow procedures.

3. The boric acid batching lineup was reperformed and the lineup checklist was placed in the Chemical Operations Foreman files.

4. Chemical operators were provided an extensive briefing covering the Conduct of Operations which specifically addressed:

a. verbatim compliance with procedures

b. systen lineup checklist retention requirements

5. Chemical operations procedures were reevaluated to determine whether they needed to be on station during performance. Direction has been subsequently issued specifying those procedures necessary to be physically present and used to assure compliance.

6. Copies of the current chemical operations system lineup check lists have been obtained from ODCC and are located in the chemical operations system status file. In addition, chemical operations quality related system lineups will be reperformed in order to update the chemical operations system status files.

IV. Corrective Stees Taken to Prevent Recurrence HL&P is currently taking the following actions to prevent recurrence of the conditions resulting in the violaticn.

1. Briefings of Chemical Operators have been completed for 44 of 54 individuals. Most of the chemical operators employed at the time of this violation have been briefed. Eight of the newly hired chemical operators and two operators employed at the time of the violation still need to be briefed. Remaining briefings shall be completed prior to February 1, 1988.

2. Of the 28 chemical operations quality related system lineups at STP, 24 have been verified. The remainder (pending valve accessibility) shall be completed prior to February 1, 1988.

3. HL&P will revise Chemical Operations and Plant Operations procedures prior to July 1,1988, to provide a better mechanism for the operators to status what steps have been performed during an evolution.

NL. RESP. NOTICE

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Attachment ,.

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File No.: G2.4 Page 3 of 3 V. .Date of Full Cn=nliance

'l STPEGS will be in full compliance by February 1, 1988. Additional r preventive measures will be completed by July 1, 1988. (

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NL. RESP. NOTICE I

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