IR 05000498/1986026

Insp Repts 50-498/86-26 & 50-499/86-24 on 860901-1103. Violations Noted:Failure to Follow Procedures Involving Hold Tags on Nonconforming Items

ML20215D707
Person / Time
Site:	South Texas
Issue date:	12/06/1986
From:	Breslau B, Bundy H, Carpenter D, Constable G, Kelley D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215D697	List: IR 05000498/1986026 ML20215D694 ML20215D705
References
50-498-86-26, 50-499-86-24, NUDOCS 8612170007
Download: ML20215D707 (13)

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APPENDIX B'

, .4 U. S. NUCLEAR REGULATORY-COMMISSION REGION IV-

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NRC Inspection Reports: 50-498/86-26 Construction Permits: CPPR128

.50-499/86-24 CPPR129 Dockets: 50-498 Expiration Dates: December 1987 50-499 December 1989 Licensee: Houston Lighting '& Power Company (HL&P)

P.~0. Box 1700 Houston,_ Texas- 77001 Facility Name: South Texas Project, Units 1 and 2_(STP)

Inspection At: STP, Matagorda County, Texas

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Inspection Conducted: September 1 through November 3, 1986 Inspectors: /2/c/94 D. R. Carpe'nter, Senior Resident Inspector Date'

- Project Section C, Reactor Projects Branch

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/p'. A. Breslau,- Project Inspector, Project Ddte Section C, Reactor. Projects Branch

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}H. T. Bundy, . Project Inspector, Project Date Section =C, Reactor Projects Branch

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11/t/91 Dath

/hD.' Kelley, Senior Resident Inspector Comanche Peak _ Task Group 8612170007 e61210

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PDR ADOCK 05000498

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. Approved: , =

G. L.WaEle, Chief, Project Section C Date

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. Reactor Projects Branch

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Inspection Summary

' Inspection Conducted September 1 through November.3,1986 (Report 50-498/86-26; 50-499/86-24 ,

Areas Inspected: Routine, unannounced inspection including site tours, licensee action on previous inspection findings, allegation followup, preoperational test program' review,~ preoperational test witnessing, preoperational testing QA/QC

.' procedure review, preoperational test procedure rev ~ w, preoperational test .

results' review and nonconformance report (NCR) hold tag Results: Within the areas ' inspected, one violation, with two examples, was

- identified (failure to follow procedures involving hold tags on nonconforming

~1tems, paragraphs 6 and 10).

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y-3-DETAIL .

. Persons Contacted Principal Licensee Employees

• D. R. Bednarczk, Operations QA-Supervisor D. J. Cody, Manager, Nuclear Training Department

• R. Daly, Startup Manager

• S. Dew, Deputy Project Manager

' *W. P. Evans, Project Compliance _. Engineer

• S. Head, Lead Project Compliance Engineer

• J. Hughes, Startup-

• T. J. Jordan, Project QA Manager

• J. H. Goldberg, Group'Vice President, Nuclear

• J.- E. Geiger, Manager, Quality Programs

'*W. H. Kinsey, Plant Manager

• A.' C. McIntyre, Principal Engineer '

• S. D. Phillips, Project Compliance Engineer

• G. B. Rogers, Construction Manage *T. M. Sobey, Manager, Plant Completion

'M. T. Sweigart, Operation QC Supervisor

• R. Hegeons, Operations QA

• S. M. Franzone, Technical Support' Engineer

• J. T. Westenneier, Project Manager M. R. Wisenburg, Manager, Nuclear Licensing

• A. McBurnett, Site Licensing Bechtel Power Corporation (Bechtel)

• L. E. Davis, Construction Manager

• L. Hurst, Project QA Manager

• R. H.'Medina, Lead QA Engineer

• R. W. Miller, Deputy Project QA Manager

• D. L. Long, Unit 1 Construction Manager

• F. Andrews, HVAC Engineer Ebasco Service Inc. (Ebasco)

• A. M. Cutrona, QA Manager

• D. D. White, Site Manager

• R. M. Zaist, Construction Manager

• S. Bodnarco Westinghouse

• A. Hograth, Site Manager

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In. addition to the above personnel,'the NRC. inspectors held discussions with various licensee,- AE,- Constructor, and other contractor personnel

' during this inspectio :* Denotes those individuals attending the exit interview on November 3, 198 . Site Tours

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The tRC inspectors conducted site tours both independently and accompanied

. by licensee and contractor personnel. These tours were made to assess the

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protection of inplace safety-related equipment, plant status 'and to .

observe construction,. testing, and maintenance activities. The areas 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 i Building; Unit 2 - MEAB, FHB, and RCB; Balance of Plant (B0P) - warehouse l and' equipment laydown areas, nonsafety support. facilities.

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! During-the course of thisl inspection, the NRC inspectors made several l

observations in the areas ~ of electrical cables and switchgear which were subsequently discussed with licensee personnel. Primary observations were:

, : Provisions for protection of cables were questionable in several areas _where work was in progress in the vicinity of class IE cable tray z Potential fire hazards were observed in several areas where material was being store Because of the above observations and the increase in preoperational testing activities, it was observed that the licensee may find it useful

to increase area surveillance in order to maintain better control of safety-related activities. Although Unit 1 is still under construction, it is also in a transition mode where testing is being completed for more equipment and systems and the unit should be increasingly controlled like an' operating power plan No violations or deviations were identifie . Licensee Action on Previous Inspection Findings

(Closed) Open Item 498/8620-03;499/8619-01 This open item concerned the use of stainless steel identification tags affixed with stainless steel cable to the rollers on safety-related microswitches and to the yoke assembly of a safety-related air operated valve (A0V) in such'a manner as to inhibit the proper operation of the component. The licensee has performed a walkdown of selected valves and microswitches and concurs with the NRC inspector that the current method

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T t c-5-of affixing metal identification tags to some microswitches and A0V's could preclude the proper operation of the A0V or other components that would rely on the output of the microswitch. The licensee has committed to change the method of identification on the microswitches to other engraving or bonding the tag to the body. On the A0V's, the tags will be ,

relocated to a different area in the valve so as not to interfere with the position incicator or valve steam operation. The changes will be made by the startup DepartmentNPOD).

(group The priorNRC to turnover inspectortohas thedetermined Nuclear Plant Operation that these actions are acceptable and considers this open item close (Closed) Unresolved Item 498/8620-04 This unresolved item concerns the construction hold tag found on valve 00-0132. This tag was a construction hold tag while the system

[No.12 Emergency Diesel Generator Fuel Oil Storage Tank (EDG-FOST)

Emergency Fill] had been turned over to startup and should have had the hold tag rolled over to an operations hold tag, if the nonconforming condition still existed. There also appeared to be an inaccurate description of the nonconforming condition on the attached hold ta Based on the investigation by the NRC inspector and the licensee, several discrepancies were identified (see paragraph 10). Thus Unresolved Item 498/8620-04 is closed and replaced by apparent Violation 498/8626-01;499/8624-0 No additional violations or deviations were identifie . Allegation Followup: 4-85-A-067 On June 6,1985, an alleger stated that potential for use of out-of-calibration torquing equipment existed at STP. The alleger said that following the torquing of items under construction the equipment is returned to the calibration shop, and upon examination, if found to be out-of-calibration, there are no attempts to go back and recheck the work which had been done with this equipment while it was out of calibratio The NRC inspector has conducted several inspections of the Measuring and Test Equipment Laboratory (M&TE) to review selected procedures and compliance with the M&TE control program. The inspector conducted discussions with M&TE, craft, and QC personnel. Additionally, the inspector reviewed related general surveillance reports, standard deficiency reports, and M&TE history files. The NRC inspector concluded that the licensee has an effective M&TE control progra The licensee, in response to the alleger's concerns, has performed a 100 percent review of deficient controlled M&TE reports to determine whether engineering evaluation responses were clear and each addressed the out of tolerance issue. The licensee's results indicated several responses to be vague; each vague report received additional engineering

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-6-evaluation. The licensee's final disposition from this review showed no

. nonconforming conditions and no impact on associated documents. The NRC inspector performed an independent inspection of the M&TE history files and found no evidence to substantiate the allegatio The following NRC inspection reports are also ger.nane to the above allegation:

498/85-07 This inspection noted two (2) violations, one 499/85-07 dealing with failure to follow procedures and the other with failure to have a procedur '*

498/85-12 This report provided overall assessment of M&TE 499/85-12 progra *

498/85-14 This report reviewed corrective actions of the 499/85-15 two violations above; finding adequate corrective action for one violatio *

498/85-24 This report provided followup review of corrective 499/85-21 action of remaining violation, improvement was noted but results were not satisfactor *

498/86-05 This report revealed significant improvement, closing 499/86-05 remaining violatio /86-20 This inspection was conducted as a followup of M&TE 499/86-19 program to ensure compliance. Adequate performance was note Based on the above, this allegation is considered close No violations or deviations were identifie . Preoperational Test Program Review The NRC inspectors conducted an inspection of the licensee's preoperational test program. The following documents were reviewed to determine the licensee's commitments and for controls on the conduct of tests and the certification of the result FSAR, Chapter 14 Regulatory Guide 1.68 Startup Administrative Instructions REVISION Startup Manual Use and Control 1 Startup Organization 1 Startup Quality Assurance Plan 1 Equipment Clearance 2 Release for Test 1

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Preventive Maintenance Program: 2 Master Completion List ,

- '4 Control of Measuring and Test Equipment 2 Indoctrination Training and Certification

! of Test Personnel '3 Startup Work Requests 8:

Problem Identification and-Resolution Configuration Control Package 2 Temporary Alteration Control 3 Material Control and Vendor Services 4 Review of Startup and Operating Experiences 1 i Prerequisite . Testing - 9 Preoperational Testing 3-

> -Turnover to Operations- 1

Conduct of Startup Operations 0 l Pre-RFT Cleaning Program 0

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The test program appears to contain the required elements and controls as set forth in the Startup Administrative Instructions.

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No violations or deviations were identified.

l Preoperational Test Witnessing

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Portions of the following preoperational tests were witnessed:

t 1-CV-P-01 CVCS Charging, Letdown and Seal Injection System 1-CC-P-01 Component Cooling Water System, Train A 1-CC-P-02 Component Cooling Water System Train B

! 1-CC-P-03 Component Cooling Water System Train C

1-HZ-P-01 Essential Cooling Water Intake Structure HVAC System

! 1-RH-P-02 Residual Heat Removal System Performance Test Train B 1-RH-P-03 Residual Heat Removal System Performance Test Train C

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1-EW-P-04 Essential Cooling Water Flow Balance During the course of testing, the NRC inspector noted that the latest revision of the test procedure along with approved test change notices, were available and in use by the test personnel. The NRC inspector noted that tests were stopped when appropriate for clarification or problem resolution. The test engineer adhered to procedures for the interruption and continuation of an interruptive test.. The tests were performed as required by the approved test procedure .While witnessing the testing of 1A cent'rifugal charging pump (CCP), the NRC inspector noted a startup hold tag, SM-3278, attached to CCP 1A which indicated the component had " bearing and shaft" damage. Further investigation revealed that the licensee had corrected the deficiency but l

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l failed to follow administrative procedures for removing the hold tag after i transfer of the replacement components taken from Unit This is one  !

example of an apparent violation that is further discussed in paragraph 1 No other violations or deviations were identifie . Preoperational Testing QA/QC Procedure Review The NRC inspector reviewed the licensee's Quality Assurance / Quality Control Procedures as it relates to the preoperational testing progra The QA/QC Procedure review was to ascertain that it contained the following for control of testing activities:

Review of Preoperational Test Procedures Monitoring of the Conduct of Tests Review and Tracking of Test Deficiencies Review of Completed Tests Document Control Control of Measuring and Test Equipment Field Changes and Modifications Maintenance During Preoperational Testing Quality Assurance Records Cleanliness Control The QA/QC procedure and inspection guidelines listed below were reviewed utilizing the above as the benchmark for acceptance:

Quality Assurance Implementing Procedures Number Title Revision QAIP Organization 2 QAIP Indoctrination and Training 3 QAIP Certification Requirements 2 for Site Surveillance Personnel QAIP Document Review 2 QAIP Standard Format for Writing and 4 Controlling Procedures and Manuals QAIP Records Review 2 QAIP Surveillance 4 Quality Control Implementing Procedures Number Title Revision QCIP Inspection Reporting 2 QCIP Area / Systems Turnover to Nuclear 0 Plant Operations Department

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b-9-fQCIP Inspection Planning 2

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QCIP Certification.of Inspection, 0

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Examination and Test Personnel Inspection Guidelines Index

' Startup. Phase QC Inspection Guidelines QC Guidelines for Maintenance on Qualified Equipment Configuration Control Package-Inspection Guidelines The NRC inspector concluded, based on the areas' examined, that the above procedures met or exceeded the requirement No violations or deviations were identifie . Preoperational Test Procedure Review During.this inspection, the NRC inspectors reviewed the following preoperational test procedures:

1-DG-P-01' Revision 0, Diesel Generator No. 11 1-DG-P-02 Revision 0, Diesel Generator No. 12 1-DG-P-03 Revision 0, Diesel Generator No. 13 The listed preoperational test procedures were reviewed to determine if the contents were in accordance with the Regulatory Guide 1.68 the STP FSAR and the licensee's administrative procedure Within the areas examined, the NRC inspectors found the procedures acceptabl No violations or deviations were identifie . Preoperational Test Results Review The NRC inspector reviewed the following preoperational tests results for technical content, compliance with the Final Safety Analysis Report, Regulatory Guide 1.68, and compliance to the licensee's administrative procedures:

1-EW-P-01 Essential Cooling Water, Train A 1-EW-P-02 Essential Cooling Water, Train B 1-EW-P-03 Essential Cooling Water, Train C Objectives of these preoperational tests are to:

Demonstrate that each Essential Cooling Water (ECW) Pump is capable of delivering design flo r- -

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Verify each ECW Pumps' automatic controls and interlocks,

. including its response to safety injection (SI), Load Sequencer,

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LStandby ECW/ component cooling water (CCW) Train Demand, and Bus Strip signals and its ability to provide start signals to the ECW Pumproom Heating Ventilating Air Conditioning (HVAC) Vent Fan *

Demonstrate that each ECW Screen Wash Booster Pump is capable of delivering design flo Verify each ECW Travelling Screen automatic controls and interlocks, including its response to SI signals and high level differential across the travelling screens to provide start signals to each ECW Screen Wash Booster Pum *

Verify the ECW Blowdown Isolation Valve response to an SI signa PK-P-01 IE Power Distribution - Train A l IE Power Distribution - Train B

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1-PK-P-02 1-PK-P-03 IE Power Distribution - Train C

. Objectives of these preoperational tests are to:

Verify each 13.8KV motor-operated switch, providing power from the preferred or emergency sources is electrically interlocked to preclude parallel operation of these source *

Demonstrate that each Train AC power system is supplied from 13.8KV Standby Bus via the associated 13.8KV feeder breaker and motor-operated switc *

Verify each 4.16KV supply breaker auto and manual controls, including response to each Train Load Sequencer, and protective relay signal *

Verify that each E1A emergency safety feature (ESF) bus protective relaying provides breaker trip and/or Train Load Sequencer start signals for an electrical fault, including

overcurrent, current differential undervoltage, or degraded voltage conditio *

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Verify each 480V ESF Load Center feeder, incoming, and tie l breakers auto and manual controls, including response to Train Load Sequence SI-P-01 Safety Injection Train A/B/C and Common Logic i Objectives of this preoperational test are to:

l l Demonstrate proper operation of High Head Safety Injection (HHSI)

, pump controls and interlocks, including response to SI, Load Sequencer, and Bus Strip signals.

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Demonstrate proper operation of Low Head Safety Injection (LHSI)

pump controls and interlocks, including response to SI, Load Sequencer, and Bus Strip signal *

Demonstrate proper operation of SI system valves response to an SI signa Demonstrate proper operation of SI system valves response to an containment isolation signal (CIS) signa Demonstrate proper operation of the Containment Sump Isolation valves during an Automatic Recirculation Switchove *

Demonstrate proper operation of the LHSI and HHSI Pump Mini-Flow Recirculation valves during an Automatic Recirculation Switchove *

Isolation valves Demonstrate interlock with proper operation the refueling of Containment water storage tank Sump (RWST) Outlet valve SI-P-02 Safety Injection Accumulators The objectives of this preoperational test will verify that the SI Accumulator system discharge and operational performances in a cold unpressurized reactor coolant system are per design requirements as follows:

Verify that the accumulator discharge flows are in accordance with design requirement Verify stroke time of the accumulator discharge isolation valves, both in a static condition and under maximum expected differential pressur Verify that the accumulator discharge isolation valves operate r

per design in response to simulated actuation signal Verify that the nitrogen and liquid charging systems for the accumulators function according to desig Verify that Containment Isolation Valve ISI-FV-3983 closes within the specified time in response to simulated containment isolation signa VA-P-01 120 VAC Class 1E Vital Power Channel I 1-VA-P-02 120 VAC Class 1E Vital Power Channel II 1-VA-P-03 120 VAC Class 1E Vital Power Channel III 1-VA-P-04 120 VAC Class 1E Vital Power Channel IV

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Verify that the Channel 120VAC 1E Inverters and Regulating Transformer provide a reliable source of 120VAC powe Verify the preferred (Inverter) and alternate (Regulating Transformer) sources can be connected to the associated distribution panel without paralleling source The NRC inspector reviewed the test results documentation and from this review determined that all the above tests met their objectives. However, it was noted that each completed preoperational test package contained the minutes of the Joint Test Group's (JTG) review plus copies of all items discussed during the JTG meeting. This additional documentation, in some cases, added in excess of 50 pages of documentation which were not germane to the test package, making independent reviews cumbersome. It would be preferable to include only documentation specific to the subject test in each completed test packag No violation or deviations were identifie . Nonconformance Report (NCR) Hold Tags On August 8, 1986, while walking down the No. 12 Emergency Diesel Generator (EDG) room in preparation for the initial rollover and run of No. 12 EDG, the NRC inspector observed a construction hold tag on No. 12 EDG Fuel Oil Storage Tank (F0ST) Emergency Fill Valve D0-0132. The construction hold tag should have been rolled over to an operations hold tag and the valve should have been conditionally released prior to system The useasspecifiedinSSP-8"NonconformanceReporting,"(Step attached hold tag indicated a Preventive Maintenance 5.2.11.6.PM) problem with motor operated valve, however, this particular valve was a hand operated valve. Several anomalies existed with this particular situation and the issue was identified as unresolved item (498/8620-04). The licensee's investigation in conjunction with their in-process QC/QA audits identified a number of nonconforming conditions with the hold tagged Valve 00-013 The construction hold tag was improper in that the manually operated valve (D0-0132), a four-inch gate valve, was improperly identified on the NCR. The valve that should have been tagged was a motor operated valve that had potential commingling of greas *

The plant system (EG) was turned over to startup (Released For Test -

RFT) in December 1985 with the valve still in the warehouse. This condition was noted on the Master Completion List (MCL) but the valve was subsequently released from the warehouse with the hold tag conditionally released for installation " prior to turnover." RFT had already occurred so the conditional release was invalid and the valve should not have been released from the warehouse or installed.

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The conditional release was violate *

The construction hold' tag on the valve was not. identified in the

- field as incorrect and requiring a rollover to an operations hold tag

+ due to the fact the system had been turned ove # -The' failure to control the" hold tag is considered.to be one of two

' - examples (see paragragh 6) of an apparent violation of SSP 8

. "Nonconformance Reporting." :This apparent violation is identified a *

498/8626-01;499/8624-0 *~

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11. Exit Interview ,

An exit interview was conducted on November 3,1986, 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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