IR 05000498/1986020

Insp Repts 50-498/86-20 & 50-499/86-19 on 860701-0831.No Violations or Deviations Noted.Major Areas Inspected: Overflow of Diesel Fuel Oil Storage Tank & Reactor Vessel Assembly.Unresolved Item Re Const Hold Tag Noted

ML20214F691
Person / Time
Site:	South Texas
Issue date:	10/30/1986
From:	Breslau B, Carpenter D, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214F675	List: IR 05000498/1986020 ML20214F672
References
50-498-86-20, 50-499-86-19, NUDOCS 8611250399
Download: ML20214F691 (9)

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U.S. NUCLEAR REGULATORY COMMISSION .-

REGION IV '

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C NRC Inspection Report: 50-498/86-20 Constraction Permits: CPPR-128 s 4

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50-499/86-19 CPPR-129 L Dockets: 50-498 Expiration Date: 3 50-499 ,, , : December,1987 ank

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. December, 1989

- Licensee': HoustonLighting&PowerCompany(k&Pk P. O. Box 1700 s

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Houston, Texas'77001 q Facility Name: South Texas Project, Units 1 and 2

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Inspection 4t:- s South' Tens Project, Matagorda County, Texas s

Inspection Cohifucted: July 1 through August 31, 1986 ,

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al-( 4-c Inspectors: h j _, /0/ '

O. R. Tatp6nter,~ SenTor Resident Inspector Ddte'

Project Section C, Reactor Projects Branch -

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S. A. Breslau, Project Engineer, Project- Ddte '

Section C, Reactor Projec'ts Brasch

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Approved:

G. L.7Eens M ef;Cfiief, Project Section C-

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Reactor Projects Branch Inspection' Summary / \  ; *'

c Inspection Conducted July 1 through.. Augyst 3N1986 (Report 50-498/86-20; ^

50-499/86-19 - - ' '

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Areas Inspected: Routine, unannounced 5inspectionincludedsitetours, overflow of diesel fuel oil ~ storage tank, reactor vessel assembly, followup on problemi ,

at other Region IV sites, measurement and test equipment laboratory, preoperational test procedure review, preoperational test witnessing, equipment tagging, nonconformance report hold tags,and preoperational' test results -

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J-Results: Within the scope. of this inspection, no vioistions or deviations were --

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8611250399 861117 PDR ADOCK 05000498 s G PDR _

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DETAILS Persons Contacted Principal Lic;nsee Employees * F. Bednarczk, Supervisor Mech /NDE

* J. 'Cody, Manager, Nuclear Training Department

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• Daly, Startup Manager ~

Dew, Deputy Project Manager

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• W. P. Evans, Project Compliance Engineer l *S. Head, Lead Project Compliance Engineer i' *J. Hughes, Startup

• T.' J. Jordan, Froject QA Manager a *J. E. Geiger, Manager Quality Programs

'*W.tH. Kinsey, P! ant Manager i *A.J'. McIntyre, Principal Engineer y *S. D. Phillips, Project Compliance Engineer i *G B. Rogers, Construction Manager

,d.T.Sweigart,OperationQASupervisor t

'*J. T. Westermeier, Project Manager

, I i M. R. Wisenburg, Mariager, Nuclear Licensing

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Bechtel Power Corporation (Bechtel)

• L. E. Davis, Construction Manager

• L. Hurst, Project QA Manager

• C. W. Humes,' Site Project Engineer y *R. H. Medina, Lead QA Engineer

• R. W. Miller, Deputy Project QA Manager

• D. L. Long, Unit 1 Construction Manager Ebasco Services, Inc. (Ebasco)

• A. M. Cutrona, QA Manager

• R. G. Peck, Deputy QA Manager J. A. Thompson, Deputy Construction Manager

• R. M. Zaist, Construction Manager Westinghouse

a,." *A. Hograth, Site Manager

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In addition to the above personnel, the NRC inspectors held discussions with various licenses, AE, Constructor, and other contractor personnel during this inspectio "

• Denotes those individuals attending the exit interview conducted on August 29, 198 .. . .;

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... Unresolved Items An unresolved item is'a matter about which more information is required to determine whether it is acceptable as it may involve a violation or deviatio One unresolved item, 8620-04, is identified in paragraph 11 of this repor . Site Tours The NRC . inspectors conducted site tours both independently and accompanied

. by licensee and contractor personnel. These tours were made to assess the protection of installed safety-related equipment and plant status and to observe construction, testing, and maintenance activities. The areas

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toured included: Unit 1 - Mechanical and Electrical Auxiliary Building (MEAB), Reactor Containment Building (RCB), Fuel Handling Building (FHB),

Essential Cooling Water Building, Emergency Diesel Generator Building and safety-related equipment of the Turbine Generator Building; Unit 2 - MEAB, FHB, and RCB, Balance of Plant (BOP); warehouse and equipment laydown areas, Reactors Operations Training Simulator facility and various nonsafety support facilitie ;

No violations or deviations were identifie . Overflow of Diesel Fuel Oil Storage Tank While filling Unit 1, Train B, Emergency Diesel Fuel Oil Storage Tank (FOST)

(nominal 67,000-gallon capacity), and overflow of approximately 2400 gallons

occurred. The F0ST is located in a vault directly above the Emergency Diesel Generator (EDG) room. This vault is designed to hold the contents i of the FOST in the event of tank failure. The overflow from the tank ran down piping penetrations in the vault floor, which had not yet been sealed. Some equipment in the EDG room got oil soaked and the floor was covered with oil. Cleanup was started and augmented fire protection

! measures were established immediatel The licensee investigation of the occurrence revealed that the assumed i volume of the tank was in error and that the calibration of the level indicator was misleading. The actual volume of the F0ST was 75,000 gallon Not the 70,000 gallons indicated on P&ID SQ 159 F00045. Thus an indicated

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74 percent level would be 55,000 gallons instead of the assumed 51,800 gallons. In addition the zero reference tap for the level

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indicator is located on the tank such that 1800 gallons of fuel oil was

added before tank level indication began increasing. The combination of these errors resulted in the addition of 71,400 gallons of fuel oil to

the tank. Since the overflow line is at 92 percent (69,000 gallons)

t approximately 2400 gallons overflowed to the FOST room floo During the filling evolution, operations personnel depended solely on one pennanent, unproven level indicator to determine the volume of oil in the tank. Although not specifically communicated to the operators

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-4-transferring the oil, it was generally understood that at 100 percent the tank would be full and pumping should ceas Information available to operations personnel concerning the tank

capacity and the scale on the level indicator was wron <

This incident points out the need for the licensee to take extra i precautionary measures during initial operation of equipment and systems being operated for the first time or during abnormal evolution Independent verification of parameters, clear and concise objectives and precautions, and directions to stop or not start testing when in doubt

should be the basic operating and testing philosophy during this phase of j construction and testin The licensee is conducting a series of actions to resolve the specific

< F0sT level problems as well as addressing the above stated generic problem No violations or deviations were identifie . Reactor Vessel Assembly The NRC inspectors witnessed the assembly of the reactor vessel internals head and support assemblies on two separate occasions during this inspection period. The first was just prior to the primary hydrostatic test (hydro). The following observations were made and discussed with the licensee. The Nuclear Steam Supply System (NSSS)

support equipment needed to perform head assembly had been available for

, checkout prior to use for a considerable time. However, the reactor vessel "0" ring installattan fixture failed to operate as designed and the vessel "0" rings were improperly stored. The above conditions required the "0" ring to be installed by hand. Subsequently, the inner seal had a small leak detected during the primar The reactor

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vessel head bolt stud tensioner lifting hoists (y hydro.three) were not installed and tested properly and thus could not be used, forcing the stud

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tensioners to be rigged by hand. These same three hoists had not had proper preventive maintenance (PM) as indicated by a leaking drum seal (caused by over filling.with grease). This was identified by the NRC

. inspectors. The sliding bridge that carries the rod drive power cables I~

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failed to slide properly causing the cables and bridge to be removed before the head was removed, i

Although there was no plant or equipment damage as a result of these

activities, the above observations reflect poor planning and preparation for a major plant evaluation on the part of the licensee and the NSSS supplier (Westinghouse).

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The second head installation was post-hydro (required to replace damaged

"0" rings) and was completed without major incident, using the proper NSSS equipment as designe , .

t-5-In conjunction with assembly of the reactor vessel system the following Plant Maintenance Procedures (PMP) were reviewed and found acceptabl PMP04-RX-0004 " Reactor Vessel Head Installation for Rapid Refueling" PMP04-RX-0005 " Reactor Vessel Internal Removal" PMP04-RX-0006 " Reactor Vessel Upper Internal Installation" PMP04-RX-0008 " Reactor Vessel Lower Internal Installation" PMP04-RX-0016 " Reactor Vessel Head Installation for Hydrostatic Testing" No violations or deviations were identifie . Followup on Problems at Other RIV Sites for STP Two recent problems at RIV sites were reviewed by the NRC inspectors for applicability to STP. These incidents were bacteria fouling of F0ST and seismic qualification of battery storage racks, Diesel Fuel Oil Storage The NRC inspectors reviewed fuel oil storage practices at STP and the licensee's program to keep water out of the fuel oil and to identify and control bacteria problems. These issues are addressed by STP in Final Safety Analysis Report (FSAR) Section 9.5.4.4 and Questions 040.20, 040.23, and 430.45N of the Questions & Answer Sectio Additionally, Technical Specification Surveillance Requirement 4.8.1.1.2 addresses these issues. STP uses Fire-Prep 8256, a distillate fuel oil treatment for bacteria contro STP's fuel oil storage is above ground, in a vault, and uses no day tank. Oil samples are drawn from the bottom of the F0ST and counted for bacteria by an approved procedure, Plant Chemical Procedure PCP2-ZB-30, Revision 0, " Determination of Total Bacteria Count." STP practices with regard to these issues appear to be adequate, Battery Racks The identified problem at another facility involved large spacing between the battery cells and the ends of the support racks. This spacing had not been considered during seismic analysis. STP has four (4) IE batteries, channels I and IV are 1800 Ampere Hour (AH)

Gould and channels II and III are 1200 AH Could. There batteries were purchased with vendor supplied storage racks. The 1600 AH batteries requires a 0.13 inch minimum end gap and the 1200 AH batteries require a 0.12 inch minimum end gap. These gaps were appropriately set at installation and verified during prerequisite testing. As a result of the NRC inquiry, the gap was remeasured and

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-6-found to be less than 0.12 inches on some rails. This is attributed to the cycling of the battery (test discharge and equalizer change)

during the recently completed preoperational testing. The licensee has issued a Startup Work Request (SWR) to have the gap reset. This finding was not considered to be similar to the original proble No violations or deviations were identifie . Measurement and Test Equipment Laboratory (M&TE)

The NRC inspectors conducted a follow-up review of the M&TE program. A review of documentation, which included M&TE recall log, deficient M&TE reports, history files and the M&TE recall log indicated adequate control was being maintaine Interviews were conducted with laboratory personnel including supervisors. Each appeared to have a comprehensive understanding of the programmatic guidelines and instruction No violations or deviations were note . Preoperational Test Procedure Review During this inspection, the NRC inspectors reviewed the following precperational test procedures:

1-PC-P-05 " Main and Unit Auxiliary Transformers" 1-HM-P-01 " Mechanical Auxiliary Building HVAC System" 1-FH-P-03 " Fuel Handling Equipment In the Containment Building" 1-CV-P-02 " Charging and Letdown Operational Verification During HFT" 1-CV-P-03 " Boric Acid / Makeup Controls" 1-CV-P-01 "CVCS Charging / Letdown and Seal Injection" 1-HZ-P-02 " IVC Space HVAC (Safety-Related)"

1-HC-P-01 " Reactor Containment Building HVAC (Safety-Related)"

1-RH-P-04 "RHR Thermal Performance" 1-RC-P-12 " Reactor Coolant RTD Cross Calibration Preoperational Test" The listed preoperational test procedures were reviewed to determine if the contents were in accordance with the FSAR, Regulatory Guide 1.68, and the license's administrative procedure . . .

-7-In general, within the areas examined, the NRC inspectors found the procedures acceptable. However, procedures 1-FH-P-03 and 1-CV-P-02, as written, may lead to hardware damage or inadequate testin For example, preoperational test procedure 1-FH-P-03, step 4.18, states that, "preoperational test 1-FH-P-02 is complete to the extent necessary to perform this test" and preoperational test procedure 1-CV-P-02, step 5.4.5, states, "preoperational test 1-CV-P-01 is complete to the extent necessary to perfonn this test."

Further guidance is required to define what constitutes " extent necessa ry. " Precautions / acceptable criteria or " notes" should be added to the procedures to provide the test engineers with specific guidance to prevent damage to components or inadequate testing due an oversight in defining the term " extent necessary." This is an open item (498/8620-01)-

pending the licensee developing a method of defining the term " extent necessary."

Another example is in preoperational test procedure 1-FH-P-03 steps 4.1.10, 7.1.17, 7.1.21, 7.1.28, and 7.1.33, which states,

" verify . . . operation smoothly without vibration."

These steps do not provide acceptance criteria for determining an acceptable vibration level. This item is considered an open item (498/8620-02) pending the licensee developing appropriate acceptance criteri No violations or deviations were identifie . Preoperational Test Witnessing The NRC inspectors witnessed portions of several preoperational tests during this inspection period. The inspection included a brief review of the approved preoperational test, walkdown of portions of the system to be tested, discussion of the test with operators, supervisors and start up test engineers, observation of the test, review of QC activities, and spot checks of the " official test copy" to ensure adherence to test procedures and proper documentation. The following tests were witnessed, in part, by the NRC inspector . " Reactor Coolant System Cold Hydrostatic Test," 1-RC-P-01

. " Reactor Protection Haster Relay Test," 1-SP-P-02

. " Reactor Protection Test Logic," 1-SP-P-01

. " Residual Heal Removal, Loop A," 1-RH-F-01

. " Safety Injection Trains (A, B, C) Performance Test," 1-SI-P-04

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. " Reactor Coolant System Pump Check," 1-RC-P-13

. "125V DC Class IE Miscellaneous," 1-DJ-P-05 The fiRC inspectors reviewed Startup Administrative Instruction 8, Revision 4, " Master Completion List" (MCL), which describes the computerized tracking system used for tracking open and incomplete items on system and components which have been released for testing to the startup grou Prerequisites to preoperational tests include the review of the MCL by the test engineer to ensure that those items outstanding will not adversely affect the test result Prior to the start of the "125 VDC Class IE - Miscellaneous" (1-DJ-P-05)

preoperational test, the NRC inspector reviewed the MCL to verify that outstanding items had been reviewed and those items not closed would not affect the test results. The review revealed that items which could affect the test results had been appropriately closed. Cor.versations with the system test engineer indicated that he was familiar with the MCL program and its requirement No violations or deviations were identifie . Equipment Tagging The NRC inspectors have observed the use of stainless steel identification tags attached with stainless steel cable to safety-related component Some of the tags and cables could interfere with component operatio Two specific examples were noted. One example is where the cable with the metal tag is looped through the roller of a valve position's microswitch. The loop and/or tag could become fouled and prevent operation of the microswitch. The switch may be intended to provide indication, interlocks, or protection. The second example involves the same type tag and cable but attached to the valve steam yoke of a remote operated valve. In this case, the tag and or cable could prevent operation of the valve stem or direct indication valve position indicato Several specific examples of both cases were discussed with license This is considered an open item (498/8620-03;499/8619-01) pending investigation and resolution by the license No violations or deviations were identifie . Nonconformance Report (NCR) Hold Tags While walking-down the No.12 EDG room in preparation for the initial rollover and run of No.12 EDG, the NRC inspectors observed a construction hold tag on No. 12 EDG FOST Emergency Fill Valve EG 288-40-4. The construction hold tag should have been changed to a operations hold tag and been conditionally released prior to system use. The attached hold tag indicated a PM problem with the motor operated valve, however, this particular valve was a hand operated valve. Several ancmalies with this

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-9-tag and its application exist and it is not clear if it is in_ compliance with the requirements of Standard Site Procedure (SSP) 8, "Nonconformance Reporting." The licensee is reviewing the various questions posed by the NRC inspectors and this item will remain an unresolved item (498/8620-04)

pending resolution of the NRC inspectors' questions and review of the requested docunentatio No violations or deviations were identifie . Preoperational Test Results Review Although minor test27 of 136has package preoperational been reviewed tests byhave the Joint beenTest completed, Group (JTG only)one

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approved, and sent to the vault. The NRC inspectors cannot complete tl.eir results review until the test packages are through the JTG. Some tests were conducted several months ago but are not yet approved by the JT The licensee is encouraged to process completed preoperational tests in a timely manne No violations or deviations were identifie . Exit Interview An exit interview was conducted on August 29, 1986, with those personnel denoted in paragraph 1 of this report. - During the exit interview, the NRC inspectors summarized the scope and findings of this inspectio ,

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