IR 05000498/1987045
| ML20237D741 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/17/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237D733 | List: |
| References | |
| 50-498-87-45, 50-499-87-45, NUDOCS 8712240160 | |
| Download: ML20237D741 (54) | |
Text
{{#Wiki_filter:. l ! APPENDIX A U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-498/87-45 Construction Permits: CPPR-128 50-499/87-45 CPPR-129 Dockets: 50-498 50-499 Licensee: ~ Houston Lighting & Power Company (HL&P) P.O. Box 1700 Houston, Texas 77001 , Facility Name: South Texas Project, Unit 1 (STP) -Inspection At: Bay City, Texas Inspection Conducted: June 23 through July 2, 1987 Inspectors: J. Calvo, NRR P. Kadambi, NRR L. Reidinger, TTC M. Skow, RIV 0. DeMiranda, RII E. Tomlinson, NRR R. Brady, ARM A. Cerne, RI D. Sullivan, AE0D W. Thomasson, AE0D J. Joyce, NRR gh - , Approved: b 9' - M 17 77 ' E. Gag [ljardo, Chief, Operations Branch Da / J{Divisich'of Reactor Safety l pspectionSummary l Inspection Conducted June 29 throuah July 2, 1987 (Report 50-498/87-45) Areas Inspected: Special announced NRC team inspection of applicant's readiness for operating the STP, Unit 1 facility.
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Results: Within the areas inspected, no violations or deviations were identified.
, Inspection' Conducted June 29'through July 2, 1987 (Report 50-499/87-45) Areas Inspected: No inspection of Unit 2 was conducted.
l Results: Not applicable.
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, L1. - ' Inspection' Objective e.
' The objective of this team inspection at the South Texas Project, Unit I was to assess the operational readiness of the facility staff to safely ' operate the plant. This inspection was designed to assess operational . readiness by examining the following: a.
Has the applicant' established'an operational plant mentality? - b.
Has an aggressive and comprehensive root cause analysis program been ' established and implemented? c.
Has an' effective trip reduction program been established? The NRC has conducted a study.of the operational experiences of commercial- . power reactors during the first 2 years of plant operation.
The results- .of.this1 study are documented in NUREG 1275, " Operating Experience Feedback ! Report:.New Plants." The lessons learned from this study are documented in Section VI of the. Executive Summary to this NUREG.- The lessons learnedL were used..to develope the inspection criteria applied to each of.the areas l . inspected.in this effort. -This. inspection was specifically designed to not duplicate any of the previous 1y' completed inspections. The routine inspection program had been completed satisfactorily and, therefore, this effort was primarily interested in determining the applicant's. readiness to proceed into the operational modes to be authorized by the operating-license.
The inspection findings of concern to the inspectors were classified as open items during the exit interview.
In the applicant's subsequent correspondence (Enclosures 3 and 4), they were referred to as observations an'd were numbered sequentially.. The applicant's observation numbers are .~ identified in the report section which identifies the concern.- It is' noted that.several of the concerns (Observation Nos. 17, 18, 27, 28, 29, 33, 34, 35, and 36) were specific in nature and did not address a ! . programmatic weakness of note. These items are not documented in the report. ~Several. concerns are identified in this report that were not specifically discussed at the exit meeting. These concerns are identified as'open items and will be reviewed during a future inspection.
Sections 2 through 9 of this report document the major findings by first listing the individual inspection criteria'provided to the inspectors and then presenting the inspection findings which'have been indented for clarity.
2.
Management Team This inspection effort reviewed the functioning of the operating , management, communications among managers, functioning of the onsite l, - - _ - _ _ _
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review committee, interaction with the safety review committee ~ (SRC), and - management's tracking of. plant status and principal activities. This review was designed to determine if the STP management staff has achieved .an operational. mentality.
a.
Is the operational management team in place and functioning?
- The NRC~ inspectors interviewed members of upper management for the South-Texas Project organization. They also interviewed.
- members of the Nuclear. Safety Review Board (NSRB)-and the Plant .0perations Review Committee (PORC). The functions and scope of .thel Independent Safety Engineering Group.(ISEG) were also . discussed with the ISEG. supervisor.
, Basedon.theinterviews;withmanagementandwiththeworking level staf.f, the NRC inspectors determined that the applicant's management team is;in place and functioning satisfactorily.. b.
.Have mechanisms been provided'to assure adequate communications ~ .between the managers? The NSRB, PORC, and regular staff meetings held by plant' management are the vehicles used to communicate between the managers. The NRC inspectors determined that the means-available for communications between' managers are adequate.
The NRC inspectors noted that a number of video tapes discussing 'the transition phase to an operating plant and summarizing the experience of other recently licensed plants were only shown to a limited number of employees. ' The applicant was informed of this. situation and was requested to consider the need to provide the opportunity to view these tapes to other employees.
(Observation No. 1) c.
To what extent is management at every level involved in the tracking of plant status, construction completion, and ongoing activities such . ' as testing? Master Completion List (MCL) status / closure Daily Work Activity Schedule (DWAS) status / closure Work Control Center (WCC) activities The NRC inspectors found that in anticipation of the impending issuance of an' operating license, the applicant's management was very much aware of every type of ongoing activity at the South Texas Project, Unit 1.
It was found that the WCC activities had L- __ -_- _-__
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received no overview by Quality Assurance (QA) or ISEG. The applicant was requested to consider the need for an independent overview of the activities of WCC.
(Observation No. 4) d.
Are the onsite and~offsite review committees staffed, trained, proceduralized (charters), and functioning? There are'three review groups involved in the South Texas Project: NSRB, ISEG, and PORC. The groups are currently functioning under their own charters. The NRC inspectors questioned the adequacy of the staffing level of ISEG based on the activities and scope of work planned for that group and requested the applicant to consider the need for increasing resources to the group.
(Observation No. 7).
It was also noted that not enough training has been given to NRSB, PORC, ISEG, and others in the review and preparation of safety evaluations pursuant to 10 CFR 50.59.
(Observation No. 2) e.
Has management assured that the responsibility for operating all plant equipment was assumed by the operations staff in a timely manner? Is all of the plant currently under operation's control? The NRC inspectors determined that the plant equipment was under the operations staff control. The interviews indicated that operational procedures were.in place to be used for conducting maintenance, surveillance testing, and other activities.
However, it was noted that the alant operators were not walking ~ down the plant frequently enoug1 to maintain a current l understanding of this situation and the applicant was requested ' to evaluate the r c.d for increasing the frequency of operator walkdowns of the plant.
(Observation No. 16).
f.
Were adequate efforts taken to minimize the number of deficiencies ! and outstanding items (01s) prior to turnover? Have the deficiencies and OIs been tracked? Based on the interviews with applicant personnel and the results of current inspections performed by the Regional and Resident Inspectors, the applicant has done an adequate job to turn over to operations equipment and systems which were nearly free of problems.
Deficiencies and OIs are being tracked via the MCL and DWAS systems.
g.
Have the preoperational and startup test programs provided emphasis
on integrated system testing? ! ! Based on interviews with several applicant employees, the NRC i inspectors determined that integrated system testing was j i l i
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conducted as part of the preoperational testing program.
Examples of such testing are: (1) engineered safety features (ESF) integrated test, (2) response of the Class 1E ESF alternating current (AC) system to the simulated loss of offsite power, (3) auxiliary feedwater s feed all steam generators, and (ystem single pump capability to 4) connection of main turbine-gt.nerator to the electrical grid. The applicant was encouraged to schedule additional. integrated system testing during the initial plant startup and low power level operations.
h.
Has there been evidence of a commitment to the goal providing training in performing surveillance testing, calibration of equipment, and troubleshooting? The interviews with applicant employees indicated that there was a structure in place for training in performing surveillance-testing, calibrating equipment, and troubleshooting. However, the NRC inspectors noted weakness in the area of training electrical technicians to troubleshoot special equipment such as battery chargers and inverters. The applicant was informed of this weakness and requested to consider improving the training in this area.
(Observation No. 32) 1.
Has there been extensive training of the onsite plant staff (including I&C technicians operations,andmanagement}maintenancepersonnel,securitystaff, designed to reduce Technical Specifications (TS) violations? The NRC inspectors determined that the onsite plant staff received training geared to reducing TS violations.
However, it was noted that no special emphasis had been given to train the plant ' staff in the peculiarities of the one-of-a-kind features governed by the TS.
The applicant was encouraged to augment training on these features for plant staff during low power level operations.
(Observation No. 8) j.
Has additional analysis and review of the one-of-a-kind, state-of-the-art features been made to minimize the problems which these features may cause during plant operations? Based on interviews with applicant employees, the NRC inspectors determined that analyses and reviews have been performed concerning one-of-a-kind features. This was confirmed during i the detailed assessment of the qualified display processing system (QDPS) by the NRC inspectors.
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k.
Have the new or one-of-a-kind features been subjected to more complete testing? The NRC inspectors determined that not enough emphasis had been placed on performing additional testing for unique features.
The applicant was informed of this determination and requested to evaluate the need for additional testing of the one-of-a-kind features.
(Observation No. 6) 1.
Have administrative controls been established to restrict surveillance testing, maintenance, or other testing activities to test only one channel per day or in some other way restrict activities to prevent scram or inadvertent ESF actuations? The NRC inspectors determined that there was a structure in place that controls plant activities and restricts them to minimize the possibility of inadvertent plant trips.
The Plant Engineering Group was responsible for all plant testing activities which were under the control of assigned test directors who report to the Unit Shift Supervisor during testing operations.
m.
Have restrictions or precautions been established regarding work in the vicinity of instrument racks during operations? Based'on interviews with applicant employees, the NRC inspectors determined that there were no administrative controls in place that set forth restrictions or precautions when work needs to be accomplished near instrument racks'during plant operations. The ~ applicant was informed of this determination and requested to ) consider the need for establishing administrative controls that will minimize inadvertent plant trips when work is being erformed in areas close to protection system instrumentation.
p(Observation No. 5) n.
What provisions have been made for extended operations at a low power level where the operability of all primary and secondary equipment can been demonstrated? Review of the applicant's startup schedule disclosed that is was the applicant's intention to demonstrate the operability of the NSSS and B0P equipment during low power level operations. As part of their routine inspections, the NRC resident inspectors will verify that equipment operability continued to be demonstrated during low power operations.
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Are there~ incentive measures to elicit excellence in operations, e.g., minimum unplanned events such as scrams, ESF actuations, and TS violations? The' applicant had not yet developed measures to promote excellence in operations.
Applicant management believed that the plant staff was motivated to achieve excellence and no special program was needed at this time.
p.
What measures have been established or are used to focus
responsibility and accountability for unplanned events, their corrections, and for preventive measures for avoiding recurrence? There are three groups which include as part of their charter the review of unanticipated events and recommending subsequent actions to avoid recurrence. The three groups are the Nuclear NSRB, the ISEG, and the.PORC.
q.
What role does management at various levels play in assuring root cause analysis and institution of preventive measures based on l lessons learned by internal and external operating events? ! The NRC inspectors determined that not enough training had been
' done regarding the preparation of Licensee' Event Repor~ts consistent with meeting the requirements of 10 CFR 50.72 and 10 CFR 50.73.
In particular, it was noted that a training weakness existed in the area of root cause determination. The applicant was informed of this situation and requested to consider the need for additional training in this area.
(Observation No. 3) No violations or deviations were identified.
3.
Operations Staff This inspection effort reviewed readiness of the operators for startup by observing shift operations, use of procedures, status of operation training on startup procedures, shift turnover, interaction with the w rk l ' control center, and other elements of the licensee staff. Simulator training on significant plant evolutions was also reviewed.
This effort was designed to determine if the operators had achieved an appropriate l operating mentality.
' a.
Monitor shift operations to observe: (1) Use of procedures.
(2) Interactions with the work control center.
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(3) Maintenance of logs and status boards.
Reactor operator (RO) logs were kept in a very detailed manner.
All plant evolutions observed were logged with accompanying comments if required. The Unit Supervisors log contained.
general statements on plant evolutions and were up to date with R0 logs. Both sets of logs reflected the entering of limiting conditions for operations (LCOs) conditions.
Shift turnover logs were completed in detail.
(4) Interactions with other work groups.
All interactions observed were of a positive nature.
Interviews with operations personnel revealed a cooperative attitude between work groups with the exception of that between operations and training. This situation appears to be improving based on-statements by interviewees. Mr. G. E. Vaughn indicated a commitment to integrate operations and training personnel in the future to increase cooperation.
(Observation No. 10) (5) Shift turnover.
All shift turnover logs reviewed correctly reflected current - plant conditions including LCOs in effect. Clocks were provided - for the operator / unit supervisor to indicate review of all applicable logs, tagging order book, out-of-service book etc.
Shift turnover meetings conducted by the off-going shift j supervisor prior to shift included all work groups.
' b.
Have the operators been given control of the plant? Do they believe j they really have control and management's support? ~ Yes.
Especially since the promotion of Mr. H. Johnson. The operating staff interviewed believed that he will represent them ! well when interfacing with upper management. They expect j management to be apprehensive during the initial phases of operation, but believe that will go away with time.
l c.
Have the operators been given extensive training designed to reduce ) TS violations? j l TS were emphasized as part of their normal training for their license.
During requalification training time was spent on TS ! revisions.
No specific TS violation reduction training was mentioned.
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d.
Has operator training emphasized: ' I i
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b% ' ,g u4 L 10, L, L (1). Operations' involving power level changes?- Yes, as part.of their license and'requalification training.
Sev.eral operators commented that due to the fact that the l ' simulator modifications were-so far behind the control - ' room, the training received was ineffective. The antithesis'of this is a training instructor comment that the simulator is only 3-4. weeks behind the control room.
Applicant' management needs to resolve this issue.
This is anopenLitem(498/8745-01).
, (2) Unique operations. required by the test programs?- Low' power physics. testing procedures and low power engineering procedures were emphasized during requalification' training.
(3) Simulator training on plant evolutions that have caused problems l .at other facilities? (See comments under (4) below) .(4) Experience at recently licensed plants The majority-of operations personnel interviewed stated that these items were covered in the' classroom and.by.a required reading book. They indicated that the simulator - was not used as a training tool to reinforce these ideas.
'(Observation Nos.'12 and 19). One operator'and one training person ~ indicated that the simulator was used for i this function. Applicant management needs to resolve this .. issue. This is an open item (498/8745-02).
j i e.
Are post-licensing procedures being used~and are they.being debugged [ with use/ experience? Post-licensing procedures were being used for all systems that had been turned over to the operations department. Corrections
were being made as the procedures were used. Operators were of the opinion that the changes were incorporated in a timely manner.
y f.
Has management stressed the importance of detail in following procedures? Do the operators buy it?. Strict adherence to procedures was emphasized by management and during training.
Shift supervisors believed that the operators may be overly cautious in following the procedures.
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HaveLthey routinely conducted thorough reviews and dry runs for plan'ned testing and have test _ schedules allowed sufficient time for-the test and-retesting? . Training!for low power physics. testing and plant testing at low power consisted.of one week of classroom / simulator. training.
- Vost'of the operations staff personnel interviewed said that there had been only one week of simulator; training since January 1987 in preparation for.startup.
(ObservationNo.11) h.. Have. surveillance tests been flagged, categorized, and scheduled to minimize'the risk of scrams -or ESF actuations?- . Surveillance tests were.s'cheduled so thatfonly'one train of ' . Equipment / Instrumentation was scheduled at any. one time.
. Instrumentation and Control (I&C) procedures reviewed contained a'section for operator review indicating any unreliable instrumentation expected'in.the test.
This section had to be.
L signed by tha. operator.~ prior to that start of the test. All I&C procedures were similarly. designed.
, , ..i.. Is-the channel in test posted on the control'pariels?. ' The char.nel in test is indicated by.."BYP IN0P" indicating panels, bistable status lights, and. annunciators.. Reactor onerators'and' shift supervisors enter the channel in-test in , their logs. There was no LC0 status' board in the control room.
' (ObservationNo.14) j How is work controlled in the vicinity of instrument racks to prevent . -inadvertent trips? The. access to the control room is controlled by the shift i supervisor to minimize crowding. 'The applicant believes this will minimize the number of persons around the Nuclear Instrumentation Cabinets.
k.
To what extent has the applicant focused attention to potential balance-of-plant (B0P) problems by: (1) Conducting additional reviews of feedwater and turbine control ~ and bypass systems? Secondary systems received " normal" attention during initial and requalification training, no extra emphasis was placed 'on these systems.
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(2): To. identify sensitivities and unique characteristics that could contribute to a transient or ability to cope with a transient? Some shift supervisors-had emphasized to their shift personnel (both-(R0s) and reactor plant operators) the importance of secondary side equipment. Training, both initial and requalification, did not place extra emphasis on this subject.
(Observation No. 8) (3) Conducting a systematic're' view of equipment protective logics . and setpoints to identify where time delays or additional channels could reduce.the potential.for. unnecessary transient' or actuation? ' ' The-applicant had not yet performed a review of protective logics and setpoints.
' 1.. Has a color coding scheme _ or other technique been used to identify i single point scram or ESF.. actuation components?
- Color' coding had not been applied to actuation switches; Color
, coding had been used to-. separate control switches for adjacent.
L ' systems. Several inadvertent pump trips had occurred. This had been corrected by background coloring of the main control board.
m.. Have cages or covers been placed over switches or racks that could provide inadvertent trip signals? No switch covers or cages had been used to cover actuation L switches, specifically reactor trip or ESF actuation' switches.
(Observation No. 9)._ The applicant committed-to placing a bdPrier around the Rod Control Startup Reset Switch, color l coding-the Reactor Trip Switch on the reactor. control panel,'and l reviewing all ESF actuation switches and their susceptibility to inadvertent actuation and adding covers as necessary. The ' inspector noted that special attention should.be given to ESF switches on the emergency core cooling panel, n.
Are the. drawings that are used by the operational staff controlled copies?' What method is used to ensure that the appropriate revision number is maintained? How many controlled copies are in the control room / auxiliary buildin'g? The control room contained one set of controlled drawings, These were kept in a flat file cabinet.
Individual drawings were removed as necessary and replaced.
During control room observation, several drawings were removed and allowed to lay around before returning them to the file. This practice could o - _. - - -. _.. _ _.. _..
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j lead to misplaced and lost drawings.
A file cabinet containing ' " working drawings" was maintained behind the main control board.
These drawings were dated and expired 30 days after issue. The document control room was responsible for ensuring all copies were current.
(Two out-of-date copies were found in the cabinet.) The turbine building operators maintain their own set of working drawings. They were maintained current by the document control room. When questioned on how the drawings were maintained current, the operations staff did not have any consistent response. Answers ranged from "when we have a slow night we go through the files and pull out all the ones that are expired" to "someone from document control comes down every night at midnight and replaces the expired drawings".
It appeared that training was lacking in this area. There was no method to ensure drawings removed by individuals were not kept after their expiration date. This practice could lead to misoperation of systems due to using out of date drawings.
(Observation No. 13) o.
Are tagging orders controlled to ensure: (1) The operating shift has a clear-idea of equipment / systems out of service? Check of the tagging order log showed 79 active tagging orders of which 12 were associated with safety-related items. The out-of-service log reflected these 12 items.
Spot check of one active tagging order was satisfactory.
No vehicle existed for determining all outstanding tagging orders on a particular piece of equipment or system.
(Observation No. 15) (2) Work orders completed are cleared from the tagging order log in a timely manner? A monthly check was made to ensure tnat all active tagging orders in the index were in the tagging order book. A quarterly check was made to ensure all active tagging orders and their individual tags were still in effect.
No violations or deviations were identified.
SAFETEAM This inspection effort reviewed the licensee's SAFETEAM program to determine if any employee concern would impact fuel load and plant i . i
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s+artup. This inspection sampled followup on substantiated concerns to verify appropriate root cause analysis and that generic corrective action
had been identified and.mplemented.
, I a.
Are any of the unresolved SAFETEAM con'cerns of-a significance which impacts on fuel load, or subsequent milestenes? Are they being tracked? The inspection consisted of reviewing'all open files, (41 total), that were potentially safety significant and if ' , substantiated could impact on fuel load, or subsequent-milestones. The applicant was informed of one concern that should be resolved prior to fuel load, 13 concerns that should - i be resolved prior to criticality and 4 concerns that were classified as " management" and should have been in Class 1.
Applicant representatives indicated that it had been their intent to close all open concerns prior to fuel load. They also indicated an intent to perform an initial review of new concerns for safety significant issues and prioritizes the files accordingly.
The SAFETEAM Program Instruction Mant.31 specified that all concerns received by SAFETEAM were to be placed into one of five categories. The manual did not specify who determines the e appropriate classification. The inspector was informed that the Manager, SAFETEAM Program performs this activity.
It was noted that there was no independent verification of the classification process.
(Observation No. 22) The inspector identified Case Files.11581, 11548, 11559, and 11564 as being classified in the " management" category when the subject matter was of a safety nature.
These four case files should have been classified as Class 1.
(Observation No. 22) The inspectors found that the classification of concerns changed during the investigative and followup process due to facts and circumstances surrounding the issues. Due to the qualification of the SAFETEAM staff and evidence that the classification of individual concerns can and did change from the initial classification determination, the inspector determined the overall classification of concerns to be acceptable.
It was recommended that an independent verification of the classification of concerns be performed to ensure objectivity upon initial receipt of concerns.
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_ , , The processing and investigation of anonymous information , related to drug use did not appear to be consi; tent.
During.
' interviews and review of case files, the inspectar noted that Mnh some instances, followup activities varied depending on the nature of the information received regarding drugs.. The inspector was not able to find consistent guidelines for the HL&P staff regardin the anonymous alleptions of (frug use.
(Observation No. 20 , The NRC inspectors found that HL&P needed to develop specific, consistent guidelines that specifically welineate followup activities for anonymous information regardino drugs especially ', ' when potentially safety significant areas cou".d be compromised
, if the information was substantiated.
b.
Has SAFETEAM effectively pursued the generic implications of the concerns investigated? , ( (See answer under d. below) y c.
Has the SAFETEAM effectively determined the root cause of the concerns which are substantiated? Has action been taken to correct the root cause? , ' (See answer under d. below) %, d.
Have concerns which were forwarded to other organizations (QA,.' ' security, etc.) been effectively investigated to deteimite generic , implications, and to determine and correct root causes?' , l t o The inspectors noted through interviews, review of records a(d observations that the responsibility for root cause and generic implications of concerns had not been clearly defined.
Vhe. , substantiated Class 1 category of concerns that were aedrernd by the QA organization were appropriately reviewed and monitored through the nonconformance program and the trend analysi: program for root cause and generic implication.
The SAFETEAM records did not consistently reflect that a reriew had been conducted to determine root cause, generic implications, and appropriate corrective actions.
(Observation No. 23) The documented evidence for root cause, generic implic6 tion, and corrective action was not contained within the SAFETEAM case ' l files regardless of the organization responsible f or resolution of the issues. This practice did not provide an auditable trail of records other than those contained within the QA program.
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l' >'e i (. $ i ' r h " i , ,, J .c }3 The processins of additionO corcerns brought to the attention , '
er i of SAFETEAM during m investigscion was inconsistent.
(Observat'or ho. 21) i
Througs interviews with every lev [1 of SAFETEAM personnel, the ! - inspector was not able to find m ans'.itent means of processing
i l additional coni: erns by the SAFE R.M that were expres. sed during l > , the investigative prw ess.
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' s The NRC. inspectors found through interviews, recordsgreviewt and l '/ observations that the overell assessment of the HL&P' SAFETEAM! ' , , ' l Pro ~am was acceptable due to the independent? of the prograt.,,. r s i, the qtialification and eqirience of the staff' and the receptneness of management in rmolution of concerns. Den, thaugn the snject, observation.:. indicated program weakners+% ' the eventual rest.dution of concarns ca determined to be / ' adequate.. Pesclition of the. ut iec, observations would / ,y > ', stre@ hek and enhance the reutpt;: processing, and resolution of ' toncerts expressed to the applicant.
No viola'./ons 6r deviations were identified.
5.
Surveillance Testing , This inspection effors reviewed the status of the applicant's. surveillance testing to suppop, ftel load, scheduling methods for surveillance, performance of rurveftlance tests, and review of test results.
The inspection inc16ded tne training and qualification of peopb performing had established 3ppropriate prn.s at aed at determining tW-the applicart surveillance. Tee impect'on wa . tices for conductir:g surveillaote over the life of the plant.
Particular emphasis was plach on' tiie integration of ^ surveillance testing, startup testing and maintena1ce activities so that operational probhms,wwld be minimized.
a.
Have all of the surveillance tests required by the Tf been scheduled for performance ~c.r the required frequency? ~ The NRC inspector-ieviewed'the JS Surveillance Program Index and . Mode Change Report and found that all required srrveillanct tests had been scheduied.
7.n one case, Sowever, the TS ( surveillance index appeared not to identify the need for
performance of a surveillance to establish operability of ;he
- ubject equipment in the required mode.
(Example: TS 4.7.1.5 Nould appear to regire successful performance of IP903-VS-0001 '
for partial stroHnq of the MSIV3 at powei, but the curve 411ance > ' only flags the fel; stroking surveillance tes; during cold shutdown.)
(Observation NL 25) . , f L__. L - -.._.
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' n b.
Have the respons!)(11tiss for reviewing surveillance results been established and are assigned individuals qualifle.d?- A review tf.the surveill6nce program indicated that the I appropr9fo assignment of responsibility _ and accountability had been madLlq > c.
Is the tracking sistem for surveillance testing capalle of providing management with a' status of the progressi- ' i . The inspaptor fay 44 thet? the tracking of TS surveiliacce activitiet/ appeared to be both adequate and timely'. a d ' Have the final' add TSs been used to generate surveillance test procedures? Does the program provide assurance that TS: revisions will result in1theiappropriate procedure revisions? The NRC inspector found that the final drait of the TS was being used. Discussions -and Giterviews with applicant personnel revealed their tintent"to update the procedures upon issuance of the license.hhdtT$. x e.
Has the plant staff terformed or observed the performance of all surveillance? ,, 'The plant staff had rot' performed,or observed all surveillance, but credit had been taken for some preoperational tests. The '4 ' NRC inspector requested exabp?es of Mode 6 surveillance r requirements, for which credit had been taken of previous ! precperational testing. The irspector noted. the usual system credit (e.g., HVA0f and spe',:ifically pursued the adequacy of preoperational test results for the AFW !, team turbine driven
pump (110. 14A, Train "D"), since TS 4.7.1.2.1 allowed entry into ' $ Mode 3 without having performed a surveilliqce test on the steam driven AFW pump.
ReviewofthetestreFU[ts,anassociated nonconformance report (HCR), and discussion with startup and engineering personnel revealed no problem which had not been properly dispositioned.
3.
. f.
Havethosewhop9rformsurveillancetestingandcalibrationsand 'T troubleshooting eqeipment received repeated training on those 't activities that could cause a trip or ESF actuation? .- \\ (See answer under h. below) ,
s I w, "gi
-p
_-. -_ _ _.
__ .- -- - _-_ - ______ - ____- _ __ _ " p t . . .
4 < , g.; Has extensive training been provided to the stafflwhich is designed
- to reduceLviolations?'
.(Seeanswerunderh'.below).
h.. 'Has training been provided to' incorporate lessonsllearned from past l experience at~other plants?
, The NRC inspector found that the overall training was generally adequate, but wasLnot totally comprehensive. The applicant's; i procedural controls (e.g., cautions) appeared.to provide'a'means of alerting personnel.of steps that could cause trouble. :The j NRC inspector 1found, however, that there was a need for more-consistency in the application of the. credit taken for remote i position indication such as the independent verification
recommended by the TMI Action Plan..The NRC inspector recommended consideration of the Operations Department Policy which would require a check of remote position indications (e.g.,~ valve) to satisfy passive surveillance requirements per the TS. The " Independent Verification" policy of OPGP03-ZA-0010 regarding the observation'of remote indication is acceptable
only 'if the remote indication positively identifies the status
of th'e component.
(Observation No. 25).
, 1.
Are post-licensing procedures being used and are they being debugged l with use/ experience? l The.NRC inspector found that post-licensing procedures were being used. The procedures were generally well written and ! adequately controlled.
l l .. Has the I&C staff been assigned responsibility for specific j equipment? l
The NRC inspector found that responsibilities had been appropriately assigned. There were no significant concerns with I&C surveillance activities, but there was a need for the j surveillance procedure or some other cross referencing system to , identify when the failure of one component's surveillance may ) affect another TS LC0 and require entry into a more severe i Action Statement.
(Example: Failure of radiation monitor under -! " TS 4.3.2.1.10.d would require declaration of an inoperable train of Control Room Makeup and Cleanup Filtration System under.
! TS 4.4.7.7 which has a more severe Action Requirement in Modes 1-4),(ObservationNo.24) { , l k.
Has the engineering staff been integrated into the I&C organization? ! i , \\ _._L-__..._________--_.____._ _ _ _ -_ ._ - - -__- --_ _ _ . _ _ _ _ _ ._- __ -_ _ _ _ - _, _ _ _ - - -__-_ - _-. _ _ _ - _ W
,, The NRC inspector found that thE engineering-staff had'been ~ integrated into the I&C organization.
1...Have surveillance tests been flagged, categorized and scheduled-considering the risk of. scram or inadvertent ESF actuation?.
- The NRC-inspector found that surveillance tests had been appropriately flagged'and scheduled. The' procedure made good use'of " Caution" statements and had numerous " Notes."
m.
.Have administrative controls ~been established'to restrict surveillance testing to test only one channel per day-to prevent inadvertent scrams or ESF actuations? ~ There.were no specific res.trictions found during the review, but the.NRC inspector believes'that the overall controls were-adequate without a need for this specific. type' of restriction.
n.
To what extent has~ additional testing been provided.for new or-one-of-a-kind features? The NRC inspector found that.the applicant's TS generally conformed to the standard TS with specifications for the STP special features being' integrated into the LC0 and surveillance requirements-of the-TS.
o.
What provisions or restrictions have been taken to assure that surveillance testing will not impact on startup testing, or maintenance in progress? The newly established Integrated Planning and Scheduling Group should effectively minimize the conflict and adverse impacts of surveillance testing.
No violations or deviations were identified.
- 7.
Maintenance .This inspection effort reviewed the preventative and corrective maintenance activities performed by the plant staff to establish'that the . licensee had appropriate practices.for scheduling and performing maintenance so that these activities would be properly integrated with plant-operations and~the startup test program.- a.
Have corrective and preventive maintenance (PM) activities been performed using post-licensing procedures and have the procedures been-updated based on their use/ experience? I - - - - _ _ _ _.. - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - - - - _ - _ - _ - _ _ ___ .
e c
- , .. -
- STP maintenance personnel were performing corrective and PM using1their own post-licensing maintenance procedures and work
. scheduling. The plant' maintenance procedures.(PMP) were extensive and as complete as could be expected at that, stage'of plant maturity. Document review showed that PMPs were being , . revised _and upgraded continually based upon feedback from maintenance craft usage and experience.. - b.
Has a program been; established to' sche' ule and track PM? d
, An extensive program existed to schedul'e and' track PMs. A large (more than 50 persons) Maintenance Support' Department existed to-support plant maintenance in the. areas'of work package planning, scheduling and preparation, and also in.the area of material control. Maintenance-operations and scheduling.were completely automated in what. appeared to be a state-of-the-art computer-based management and tracking system.. Based upon . interviews and. document review, scheduling,.contro1~,.and tracking of PMs appeared to'be satisfactory. The inspector reviewed 15 completed work packages that included a mix of corrective and preventive. maintenance; they were; checked for meeting procedural requirements, QA and quality' control (QC) involvement, post maintenance testing requirements, reference to PMP. Work and testing criteria, 'and evidence of a satisfactory work review chain.
In all. cases, the work packages were satisfactorily prepared, reviewed, and accomplished. There were no deficiencies identified in the applicant program for scheduling and tracking PMs.
c.
Have the vendor recommended preventive maintenance items been reviewed for applicability and have those PM items which are recommended by.the vendor, but not placed in the system been appropriately reviewed and dispositioned? All vendor documents relating to STP equipment were reviewed by the licensee during the preparation of the preventive ' maintenance procedures. Mostvendorrequirements(theapplicant estimated 95 percent) were incorporated into the appropriate < maintenance procedure (s). Where a preparer considered a vendor
- >-
-- requirement inapplicable or excessive, a request was made to plant _ engineering for review and judgement. Those exceptions to q vendor maintenance recommendations approved by engineering staff - were maintained by the applicant in their central file. Ten of- - these were spot-checked by the inspector and were found to be acceptable.
,
O i
c-_____-_-_________-____
_ _ _ _ _ _ _ _ _ - - _.. _ _ ____ ___ ______________ i
1 d.
What provisions or. restrictions have been established to assure that maintenance (preventive or corrective) activities will not impact on startup testing or surveillance testing in progress? Preventive and corrective maintenance were scheduled in the same document, the daily work activities schedule, as were startup testing and surveillance activ! ties. This document was prepared by the integrated planning and scheduling group and governed and controlled all maintenance, surveillance, testing, and startup efforts on the site. The maintenance support department had major input into the document for all maintenance and some (approximately 300) surveillance. This group also reviewed maintenance activities against planned surveillance activities using their own documentation.
Additionally, scheduled maintenance and surveillance activities were reviewed frequently , in various plant meetings to foresee possible conflict.
It l appeared that the licensee was' taking reasonable measures to
foresee and prevent conflict between plant maintenance and other activities.
e.
To what extent has additional training been provided for those . maintenance activities that could cause a transient or an inadvertent I scram or ESF actuation? No special training in this area had been given to the mechanical and electrical maintenance staff.
Some additional training had been provided for I&C technicians to focus on those maintenance items that might cause transients, scrams, or ESF actuations. This was included in regular I&C and solid state protective system training.
However, the emphasis on avoidance of transients, scrams and ESF actuations did not appear to be extensive; the licensee stated that additional emphasis on problem avoidance would be made during future training. The lack of a strong program in this area was considered a weakness.
This is an open item (498/8745-03).
f.
Has extensive training been provided to incorporate lessons learned from past experiences at other plants? There was no formal program to educate maintenance personnel regarding lessons learned from other plants. There were required reading lists for supervisors and crafts which incorporated material relating to operating experience, vendor NRC Bulletins and Notices, licensee event reports,(LERs), and Institute for Nuclear Power reports Operations (INP0) significant operating event report (50ERs) and safety evaluation reports (SERs).
In addition, the training department had a formal program that provided feeding of this I - -. _. _ _
- _ _ _ - _ _. .-
material and other operating experience into regular lesson plans.
However, this effort was not specifically directed at maintenance personnel. The lack of a formal program to familiarize the maintenance' staff with operating experience feedback was considered a weakness. This is an open item (498/8745-04).
g.
Has extensive training been provided to the maintenance staff which . is designed to reduce violations? i There was no evidence of formal training of the maintenance-i staff in this area.
(Such training would familiarize technicians with the limitations and restrictions on maintenance during plant operations and the fact that maintenance and surveillance activities could place the plant in an LC0 or a state of degraded operation).
Interviews revealed that such limitations and restrictions were discussed during briefings and discussions but that formal, specific training was not conducted. This was considered a weakness and is an open item (498/8745-05).
h.
To what extent has engineering been blended into the maintenance staff? The engineering function has not been integrated into maintenance. With the exception of the I&C group, there were no engineers assigned to the maintenance department. The I&C group contained several engineers degreed in electrical disciplines.
For engineering support, the maintenance staff relied first upon the systems engineers in the plant engineering department (there were more than 20 systems engineers assigned to various plant systems). Engineers from other groups, e.g., project and construction engineering, were available when required.
Maintenance staff personnel who were interviewed stated that there was no difficulty in obtaining formal engineering support when required.
Interviews also revealed that the fact that there were no dedicated engineers in the maintenance department (other than managers) did not appear to be a problem in conducting plant maintenance.
No violations or deviations were identified.
8.
. Work Control / Test Control This inspection effort examined the licensee's control of all work and test activities to ensure proper integration into plant operations and the startup test program.
_ _ - - _ _
.. __ . - _ _ __ _ -_.
_ - _ _ _ _ - _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i a.
Have controls been established to assure the control of work performed by construction force personnel? Is construction test q equipment controlled / calibrated? In general, all maintenance work at Unit I was performed by the l Unit 1 maintenance department.
If construction personnel were ' required the requirement was detailed in the maintenance work request (MWR).
STP procedures existed for formally requesting construction assistance in all areas: maintenance, engineerin operations, and others.
Both Unit 1 and construction (Unit 2)g, test equipment was closely controlled and calibrated. STP had ' established an extensive state-of-the-art metrology laboratory which controlled all test equipment. This laboratory was modern, well equipped, and adequately manned.
Less than 5 percent of instrument calibrations were performed by outside agencies and contractors. The manager of the laboratory - reported directly to the maintenance manager, at the same level as the mechanical, electrical, and I&C maintenance managers.
The metrology laboratory was considered a strength, and the attention and resources devoted to this function served to raise the leve~ of the entire I&C maintenance and surveillance effort.
b.
Have provisions been established to assure that all operational,
startup testing, surveillance testing, construction, and maintenance activities are controlled and scheduled such that one activity does not impact on another activity and lead to a trip or ESF actuation or to the reduction of the safety of the plant? A centralized integrated planning and scheduling group had been established and functioning about 3 weeks prior to the inspection.
This group prepared and published the DWAS for the nuclear plant operations department.
Interviews and a review of the group's policies, plans, and procedures indicated that this group was adequately chartered and staffed to control and schedule plant activities. There were some minor problems in implementing this new system, but identified deficiencies were being actively worked.
c.
Has training been provided to the work control / test control personnel to sensitize them to the safety, and upset impact of their actions? Interviews and documents review indicated that training was provided to the maintenance personnel who worked in the integrated planning and scheduling group. These personnel were experienced maintenance planners who had received regular plant maintenance training and who were aware of the safety
-_---
consequences of their actions.
Like other maintenance staff, they received no special training in scrams, ESF actuations, or plant transients.
d.
Have measures been established to minimize scrams or ESF acteations, such as: (1) Color coding single point actuation components? (2) Providing test jacks and bypass switches? (3) Providing. cages or covers over swi.tches or racks to prevent inadvertent signals? (4) Provide adequate grounding of equip (ment or cable shielding toEMI) t prevent electromagnetic induction instruments? The NRC inspector found that the procedural controls over surveillance and maintenance activities were good, but the installationofhardwarefeaturesotherthanthosein(3) -above were not examined. The issue of providing cages or covers over switches or racks is addressed in paragraph 3 of this report.
e.
Has emphasis been placed on integrated system tests during preoperational and startup testing? The NRC inspector's reviews of the applicant's test program indicated that the integrated system tests were satisfactory, f.
Has time been provided for timely review of test results and feedback of experience during test program implementation? Interviews with test engineers revealed that there was adequate time allotted for review of test results and feedback of operating experience.
g.
Is the startup test program designed to encourage a deliberate, evenly paced, thorough prcoperational and startup test plan that provides for minimization of carry-over of open items and resolution of deficiencies before proceeding to the next milestones? (Seeanswerunderh.below) h.
How is the test program controlled with respect to plant operations and what is the process for review and approval of the test results prior to decisions to proceed? _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _
, - - - - __ - _ - - __- -. -. - - - ___ _ _ - - -. - _ - - _ - - - - -
The NRC inspector's review of the applicant's Mode Change Process indicates that the applicant's performance was adequate.
The plant operators appeared to be sensitive to the " operability" concerns related to testing.
i.
What controls are in place for plant configuration management and for assuring that procedures, which reflect' current conditions are used? Configuration controls appeared to be part of the upfront design change implementation effort of the MWR process.
Interviews with plant engineering personnel and a sample of several current work _ requests indicated proper. attention to drawing revisions and other design change details.
Procedural controls were found to be adequate in this regard.
No violations or devistions were identified.
, 9.
Operational Experience This inspection effort reviewed the applicant's plans for integrating operating experience into their work ethic. The inspection was conducted by(a) interviewing)plantmanagers, licensing, operations}andengineering staff craftsmen; (b reviewing-related procedures; and (c reviewing evidence of where construction, startup and operating experience had.been assessed and used by plant personnel to improve plant operations.
STP has mechanisms.in place to provide for analysis of operating experience and feedback of the lessons learned to improve operations.
However, many of these efforts are of recent origin.' Although management appears to emphasize properly the importance of learning the appropriate lessons form internal and external experience, the mechanisms to do so have not functioned for a sufficient period to have made a distinctive impact on plant operations.
The Operating Experience Report (0ER) review program and the trend analysis report efforts are being implemented based on a sound record of implementation of similar activities during the construction and testing phase. There_is evidence that event root cause analysis is being performed and that the plant has made changes to incorporate lessons learned from construction, testing and external sources.
This effort, however, does not include a systematic effort to address operating experience at other recently licensed power reactors and to improve operations at STP by applying the resulting lessons learned on measures to avoid unplanned trips and unnecessary ESF actuations.
Similarly, no I special attention has been directed at assessing B0P system l vulnerabilities for causing unplanned scrams or for improved testing of B0P components that can cause scrams.
L _2___ -- _-- . _ - - E
. _--_ _--- __---_ _ _ _ - -- , u, ,
J , The details of the inspection are presented b'elow as responses to the specific criteria used in the' inspection.
, ~ a.
Has'the staff _ received appropriate-training on the lessons learned
from experiences at the' site and at other recently licensed plants? There'weresystemsinplaceto:incorporathlessonslearned-into ! ' staff training.
However, the program lacked use of specific insights from similar, recently-licensed plants regarding lessons involving trip reduction, avoidance of ESF'actuations - and' technical specification violations. Training important to accomplishing root cause analyses had not' been given to, personnel from all plant departments which would have a role in such activities,-i.e., operations, engineering, maintenance, technical support, the ISEG,.and-.the NSRB.- .The training department had a formal training program.that ! -provided for the feedback of plant and procedural changes, as reflected in several. examples of' updated or to be updated. lesson plans. ~ Further, the program had an established tracking. system .l to ensure that deficiency evaluation' reports (DERs); NRC notices i and bulletins; vendor reports; INP0 reports, e.g., SOERs and l SERs; and STP lessons learned from operating experience were ' ' appropriately addressed in updated lesson plans. The training .i department produced. monthly video tapes of lessons learned from ' plant. operations for training of plant operations. staff. Three , such tapes had been produced over the last two months.
Finally, ! the plant-specific-simulator. had already received three j modifice.tions to better model actual plant performance.
j ! Feedback of operational experience from other plants was i dependent on.INP0 screening and analysis of LERs. Some l indication that'such a process is functional was found in
documentation provided of the plant's operations staff j o evaluation of SOER 84-04, " Reactor Trips Caused by Main
Feedwater Control Problems," in which the OER coordinator directed that recommendations regarding training, procedures and design be-addressed by responsible staff..However, no specific j citation of resultant formal training nor of indication of the j ~ consideration of the LERs from recently-licensed reactors of i similar design was identified. There had not been any J-on-the-job training (0JT) program implemented, consistent with j ^ INPD findings in an April 1987 audit, even though ProcedureIP-8.18(Revision 1)hadestablishedsuchaprogram.
_The plant staff was developing a program to establish such training over the next year.
i u__-____u___________ _.
- - - _ )
The inspectors also found that there was a lack of training specifically directed at techniques for root cause analysis of operating events, even though root cause determination was evident in a number of related plant procedures, including those for non safety-related (q) systems such as that found in aragraph 4.5.5 of the procedure on station problem reporting p(0PGP03-ZA-0018, Revision 3) and in Station Standard Procedure 65- (SSP-65).
Evidence was found that training in performing review of potential safety implications of operating events and plant changes, per 10 CFR 50.59 requirements, was being provided to all plant systems engineers, b.
Have the results of the review of operational experiences led to program revisions?- There was evidence that the STP plant staff did consider and use lessons learned.
However,-lessons learned regarding trip reduction and control of ESF actuations at recently licensed plants apparently had not been sought. Such insights might be i particularly useful as the plant enters the startup phase and completes its system testing phase. Some such information was already available to.the plant management in the draft NUREG 1275; however, no evidence was found that the operating and licensing staff had the benefit of having reviewed the report.
In general, management appeared to place the proper emphasis on the review of operating experience and analysis of its applicability as derived from HRC, INP0, vendor and STP sources.
There was evidence that plant engineering and the ISEG were utilizing industry data bases for insights related to specific plant problems and that the systems engineers, with input from other plant departments, have established, and were using, a component history data base to document performance of most plant systems, including B0P systems.
The NRC inspectors found clear indication of corrective action and transfer of relevant knowledge from experience during construction to the operations staff.
For example, lessons learned regarding installation of Raychem electrical splices resulted in operational procedural modifications and retraining of maintenance staff, and problems with the emergency diesel generator high pressure fuel line were overcome by incorporation of lessons learned from Palo Verde. Problems that led to water hammer events in the CVCS, component cooling water and the circulating water systems during testing resulted in procedural and design improvements.
_ _ - - ---
.
Nuclear engineers in the Reactor Performance Group had reviewed i the plant design over the last 10 years from the perspective of plant reliability, maintainability and operability, which had
resulted in a. number of design improvements. For example, the ! secondary side deaeration capacity was-increased to full flow j capability, full flow demineralizers were added to the feedwater . system, and the startup feed pump design was modified. The deaerator capacity and the startup feed pump changes will
provide plant operators more time.to effect adjustments in - operation to avoid trips associated with the secondary side of the plant. The same group reviewed a water hammer event in the BOP circulating water system for safety significance. The resulting recommendations for plant improvements demonstrated the care that this group exercises in consideration.of significant operating events.
. ' No systematic or specific effort had been'made to elicit information from other'similar plants licensed in the last few years regarding trip reduction measures and means to avoid unnecessary ESF actuations.
Similarly, no indication was found of specific design reviews of B0P systems for vulnerabilities to cause scrams or ESF actuations, as had been demonstrated by-recently licensed plants.
However, some specific causes were found in which the plant staff had pursued experience from other , plants on certain plant systems, as indicated below, and of j application of lessons learned from an INP0 SOER on feedwater ' systems causing scrams (SOER 84-04).
No indication was found that special testing of components or systems had been conducted or was planned to incorporate lessons learned from other reactors.
This was dependent on INPO screening of such experience, and new plant operating experience had not yet reached the INP0 report stage. Experience at plants such as Vogtle, Byron, Braidwood, and Shearon Harris might prove to be useful in avoiding unnecessary scrams and ESF actuations.
For example, the Vogtle startup experience identified a number of lessons learned for steam generator level control, such as i directing more attention to tuning control circuits for individual feedwater regulating valves and steam dump valves, improved procedures for transition from use of bypass flow regulating valves to main feedwater flow regulating valves, and less conservative settings for trip points. Although the applicability to STP was uncertain, no evidence was found that a . review of the Vogtle experier;e had been conducted.
j Specific efforts by plant staff to study operating experiences from other plants were identified in a number of areas.
Specific relevant experience was sought in the area of emergency I _ _ _ - - - - _
_- J '
p I ' ' p E
( ~ diesel generators.. Personnel were well-appraised of problems experienced at similar units. Although the contacts were.
informal, it_ appeared that lessons. learned 'were feedback into-the conduct of operations.. The experience-at Palo Verde,. ~ resulted'in revision of STP maintenance' procedures.
Further, , informal' inquiries regarding troubleshooting procedures at Duke ' Power. Company plants and Crystal River and radiation monitoring system experience.at plants that.have'the same system as.STP, had been utilized to address possible. improvements to the STP . operations. However, the latter was limited by funding . restrictions'so that the staff was restricted from participating in a users group.'. Personal contacts and use of consultants did provide. insights to' anticipated problems.
The only change in the radiation monitoring system that was specifically identified was a software improvement based on insight from Hope Creek.
Lessons learned from recently licensed plants, such as San 10nofre 2 and.3 and.Palo Verde regarding radiation monitor hardware, improvements to-eliminate possible electronics noise and grounding problems'were considered undesirable' based on system operational = aspects, c.
.Has high visibility been give'n to the sources of unplanned trips and actuations caused by human error? Other than with the reactor' operators, the only specific point of accountability that was found was with the systems engineers who are accountable for.the successful operation of the assigned systems. The 40 or so l systems engineers serve as " field engineers" who work closely with startup crews and the maintenance department in; overseeing the oaeration of'various plant systems. Each of the plant systems las a system engineer, as the focal point for all documentation regarding the. system.
The only other indication of individual responsibilities as related to a specific class of equipment was that some mechanical, I&C, and electrical craftsmen had received specialized training on maintaining the emergency diesel generators. Otherwise,-no evidence was obtained that training or the assignment of individual responsibility was considered in relation to accountability and providing for-lessons learned feedback to control unplanned trips and ESF actuations.
However, if used properly, the plant does have record systems in the-form of equipment history, work control systems, trend and , pattern analysis and performance ~ indicators that could provide a means to identify recurrent personnel errors.and to develop feedback through 0JT, once it is established.
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d.
Has the operational experience feedback program concentrated on the root cause of the problem (internal or external) and addressed the measures to prevent recurrence? The STP plant operations departments appeared to have the ~ fundamental systems in place to effect a good root cause analysis and feedback of the operating experience to the responsible departments.
Further, there was documentation that the experience was being used to enhance plant operations. The ' procedures and the work sheets for event investigation clearly called for root cause determinations, which were to be i accomplished under the leadership from the department responsible for the equipment and the remedial work.
In response to the overview of the NSRB, the various plant problem reporting systems had been reviewed by the operating department licensing group leader, who had made a number of findings regarding weaknesses in the overall program and recommendations,for refining and improving the program. The result of the review was a new procedure that will consolidate 11 related procedures and will provide more discipline and centralization in the information flow and reporting process.
This procedure was scheduled for completion by the end of July 1987.
In the meantime, programs were in place and obviously being implemented to address root cause analysis of plant events and to feedback lessons learned from plant events and external l sources. The latter was particularly illustrated by the careful consideration of NRC information notices (beginning with IN 79-01), bulletins (beg) inning with IEB 70-09), and circulars i (beginning(with IEC 76-01.Four examples were reviewed that l ' indicated 1) current review or rereview of the NRC documents for lessons learned; and (2) transfer of the lessons to the operations department affecting procedures, training, and hardware for safety-related and nonsafety-related systems.
The inspectors reviewed the response to water hammer events that occurred during testing in the CVCS containment isolation letdown line, the RdR heat exchanger discharge line, and the ! circulating water cooling system. The review of the first two events demonstrated attention to root cause investigations and implementation of corrective action. Other reportable 10 CFR 50.55(e) events that indicated not only root cause analysis but also transfer of lessons learned to the operations department were reviewed. These included protection against-
microbiological induced corrosion, use of Raychem splices in i electrical systems, and unnecessary, load-side terminal bus bar extensions on molded-case circuit breakers. The latter provided some indication that, at least during construction turnover, the i i - _ _ _ _ _ _ _ _ _ _ _ _.
_ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ __ _ _ _ ___ _ _ _ _ _ _ _ _ - _ _ _ _ _ i J l
) i I established recurrence control program was not. totally effective; the problem previously had been identified and i measures, including training and guideline development had been taken to avoid recurrence.
. Review of the circulating water cooling system water hammer event, an cvent associated with a nonsafety-related system, provided the NRC inspectors an example of a quality effort of root cause analysis as well as a good. analysis of potential safety implications had the event occurred under other conditions. The NRC inspectors also addressed the operations staff use of lessons. learned from other plants that have the , t l-same Cooper Bessemer emergency diesel generators.
Vendor and ' selective operating plant experience, in particular from Palo Verde, was used to implement design and procedure changes to improve the reliability of the diesel engines. One example of a less than timely but ultimately successful root cause analysis and implementation of a corrective action by the maintenance department was identified. This involved the recurrent failures of the battery charger inverters.
In these events there were a
number of problems associated with the inverters. The initial response was to merely change the circuit cards; however, ultimately, with the aid of a vendor representative, the root cause of one repetitive failure was identified as the lack of cooling grease in the inverter, even though the procedures identified the need and the grease was in stock in the warehouse.
The post-licensing operating event report (0ER) review program was reviewed, including a number of procedures that relate to the documentation, review and analysis of station problem reports (SPR) and NCRs; external sources of operating experience, i.e., from INP0, NRC, or vendors; and LERs, per 10 CFR 50.72 and 50.73 requirements.
This effort, under the direction of operations licensing support, will be an extension of the well-demonstrated relicensing construction defects and
problem reports review effort headed by the applicant's licensing department.
e.
Has the independent safety evaluation group been actively involved in analyzing events and recommending strong corrective action? The ISEG began functioning in early May 1987.
It had issued two reports, including one addressing B0P deficiencies, that ,. reflected active involvement in review of plant operations and I strong conclusions regarding needed areas of attention by operating line management.
However, there was yet to be - _ - _ _ _ _ _ _ _ _
W '
o " '
z developed a program for assuring that corrective actions suggested by the.ISEG were subsequently addressed and closed L out.
The ISEG was composed'of a director and five senior technical-staff.- The group was' constituted by a " philosophy document"- dated February 9,.1987, and operated under the auspices of the LNSRB.
It had no line review responsibilities but operated under a mandate _to investigate.and probe into the.' root.cause of operational ' events, management. system ~ problems' and undesirable l trends.
Half of the staff's time was to betin the. plant ' . observing control room and local; station operations and , monitoring maintenance.and special plant' evolutions. Since the.
ISEG was staffed in mid-May, emphasis had been pl. aced.on-providingLtraining.. on methodology for. observing operations and documenting findings on the observations.
Two ISEG reports were issued for comment ~just prior to the inspection and demonstrated the extent of the ISEG oversight'of.
,, activities that relate to B0P operations but can clearly-influence plant' safety and reliability. The first report of observationsLand investigations'into " Manual Remote Valve Operators" (ST-HS-P2-156) contained five. conclusions that - questioned the adequacy of: stroke testing of valves equipped with remote manual operators and the adequacy of procedures and equipment-operator training in accomplishing the testing. The second report involved ISEG observations of " Reactor Plant Operator: Pre-Shift, Shift Turnovers, Rounds, and Shift.
' Activities"- based on the observation of two reactor plant operators (auxiliary operators).in the mechanical electrical auxiliary building and one each in the turbine-generator building and the plant yard.
In this report the ISEG. reported-six conclusions that raise significant questions regarding the adequacy of training and procedures of this category-of plant staff.~ These reports clearly illustrate the breadth and thoroughness of the ISEG involvement.
However, the reports were only distributed to a limited set of responsible plant department managers with the statement, "If any corrective actions are taken, they are at your discretion.
Formal feedback to ISEG is not required." Thus, it is unclear that there was a formal program to ensure that ISEG conclusior.s would be carefully considered, tracked, and closed out, at least as they pertain to nonsafety-related operational matters, that were the focus'of-these examples.
Subsequent communication with the applicant indicated that the valves whose stroke testing had been questioned by the ISEG had i been tested subsequently or had been verified to be adequate. A , - _ _ _. - _. -
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_ ._ - _ _ _.-___ ____-____-____ - - __ _ _ f I L L
i response and plan for addressing the other ISEG conclusions and to develop a mechanism for managing'and closing out ISEG L conclusions and recommendations was promised by the applicant.
.. , f.
Has the licensee developed'an effective post-trip review program that
will preserve' evidence and data and permit accurate determination of l root causes? .
. Plant' Procedure OPGP03-20-0022 provided the detailed framework for conducting post-trip reviews. There were two sources of- ! computer printouts that were. generated following reactor scrams j that.provided. plant sequence of event.
The sources were the Emergency Respose Facility Data Acquisition and Display , System (ERFDADS).and the PROTEUS computers.
Both sequence of events records were used forl completing the required specific - data. sheets along with information from strip' chart recorders.. These systems.were responsive to post-TMI~1essons. learned, e.g., NUREG 0737, and to Generic Letter 83-28. Additionally, the trending function within the operations QA department was designed to aid in'the determination of'~causes by. examining the historical record of parameters found to be responsible for
events.
It was apparent that sufficient data would be available to conduct a thorough post-trip review.
g.
Has'the licensee develope'd an adequate trip reduction program? Does the program include B0P as well as safety-related equipment? The trip reduction program regarding event analysis and corrective actions appeared to be well established and included B0P events.. However, except-for a response to SOER 84-04 and the use of Westinghouse trip reduction program insights, there had not been a specific effort to consider initial operating-experience at other recently-licensed, similar power reactors.
Thus, the proactive trip reduction efforts had been less than desirable for the lack of detailed review of: (1) B0P-vulnerabilities to cause trips,-(2) possible improvements of.B0P testing, (3) BOP system trip logic and setpoints, and ' (4) adequacy of protection of switches and control panels from inadvertent actuation by bumping.
Three activities were identified that comprised the station's trip reduction program. The broadest function was the cause'and corrective action program which addressed station problem L reports and also included the review and evaluation of l: externally generated operating experience reports provided by the licensing staff.
This effort encompassed the steps necessary to determine whether an event was reportable under 10 CFR 50.72 and 50.73 and to develop an LER. The post-trip , - - _ - _ _ - _ _ _ _
l l ' review program was a subelement under the cause and corrective action program.
It had been developed to respond to Generic I Letter 83-28 and was based on INP0's good practice guidance.
The final activity was involvement in the Westinghouse trip reduction program. A shift technical adviser (STA) had attended the vendor meetings on trip reduction, which included contact with licensed plant representatives. Also, the STA reviewed all WCAP documents related to trip reduction for lessons learned applicable to STP.
However, over the past year this proactive effort had been "on hold" during prep 7tions for plant startup.
Other than normal reviews of plant system designs for operability, reliability, and maintainability by the STAS and plant engineering staff, the only indication of special reviews performed for system vulnerabilities to unnecessary trips was response to a SOER, as discussed below. Consideration of matters, such as actuation logic, design, unprotected switches, and trip point settings that have been shown to be problems in newly licensed plants, apparently had not received special attention.
Similarly, no indication could be found that startup test experience on B0P systems from other plants, such as the turbine bypass valves and the feedwater control systems, had been considered in planning or conducting STP startup tests.
The station problem report on the floodir.g of the cooling w)ater pump bay from the rupture of a pump casing (March 17, 1987 and the response to SOER 84-04 regarding reactor trips caused by main feedwater control problems.provided insight to the quality of reviews of B0P system events and of responses to external sources of lessons learned. The latter included action items for relevant plant departments to review the lessons learned and to apply them to the STP plant.
Both items reflected the care and attention being directed by the STAS and the plant staff to lessons learned to improve plant operations.
h.
Is there assigned responsibility for trending equipment performance and failures? There were clearly assigned responsibilities for trending plant equipment performance and for maintaining an equipment history.
Further, there were a number of complementary trending activities that should provide valuable insight to address plant problems and improve plant operations, if they were satisfactorily implemented.
The systems engineers were responsible for maintaining the f equipment history data base that included input from maintenance j work records. Once a data base had been established on a l i
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component or. system. the, plant department responsible fur a. particular work order would input the data. The: data base was established.in early 1987; however. historic: data on'the ' equipment will be reviewed by the system engineers for possible t-entry to the: data base. The systems engineers also.had a-
- dominant responsibility for review and evaluation of the data
, -_and were instrumental-in developing the analyses.for the QA - department that prepared periodic. summary trend reports for plant management.
The construction'QA' organization, which was'a part of'the plant ' QA department, had_been responsible for trending performance ' during construction and testing. The operational trending program will_be built on the successful construction phase - program.- In addition to the QA trending reports, the ISEG had established two data bases and intended to trend its observations and possibly the deficiencies the ISEG identifies during' plant tours. This-activity', however, had not been fully developed at the time of.the_ inspection.
Finally, the plant planning and scheduling group ~was responsible for maintaining the performance indicator program and for, issuing periodic summary reports to the plant manager.
1.
How do the operating experience and lessons learned get feedback to theoperationsgroups,suchasinstrumentandcontrol(I&C), maintenance, engineering / design, and operations? The focal point for synthesis of operating experience was the licensing department, which was the clearinghouse for all external reports and managed the LER program.
In this' role the department distributed the 0ERs to the departments that would have an. interest or a specific capability for assessing the" information for lessons learned applicable to the STP. Further, the licensing group was responsible for ensuring that all LERs were tracked and satisfactorily closed out, including root cause analysis and for tracking action items resulting from OER reviews. During the. transition from construction to operation i thisfunctionwasfulfilledthroughfollowupof10CFR50.55(e} reports.
-The maintenance planners utilized the equipment history data base in planning maintenance and I&C work orders. The systems engineers, who work closely with the maintenance and I&C craftsmen, provided another means of. lessons learned feedback.
Also, as the OJT program is. developed over the next year, 0JT will be used to complement the more formal training provided by , the training department in providing information feedback.
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L The operations staff was provided with periodic video tapes, produced by the training department regarding lessons learned during the previous month on particular problems such as the use of procedures. The plant-specific-simulator will be used to provide experience in responding to particular events, including normal plant evolutions during startup.
The simulator was currently limited to only three events at other plants and to the STP RHR water hammer event.
The operators had only' limited opportunity for such training.
Generally, from the time the various plant equipment and systems had been turned over by construction for testing, the plant systems engineers and maintenance and I&C staff had been
involved with thef equipment and had responsibility for its i preventive and some corrective maintenance. They had also been-j closely involved with the repair of the turbine generator, - emergency diesel generators, and the feedpump turbine. About
half of the I&C technicians and many mechanical system craftsmen ] had been involved with startup testing. The electrical i department staff had more limited experience on the operating J equipment'during the relicensing startup testing phase.
(Observation Nos. 30 and 31) j.
Describethetopdown(managementorengineering)andthebottomup (maintenance or I&C) mechanisms for feedback and assessing of operational experience.
The inspection findings of the " top down" flow of lessons learned were described above.
The " bottom up" flow was exemplified by the responsibility of all staff to document any identification deficiency in a maintenance work request (MWR) or a SPR and by responses required under standard site procedure (SSP) 65. These actions were to result in attention to the potential deficiency by the person's immediate supervisor and then by the responsible department for analysis, provided that the supervisor agreed that there was a problem.
In ! addition there can be job debriefings and the craftsmen were to l complete a connents section on the MWR with information related to the completed work.
Finally, the department performing the work was to provide input to the equipment history data base.
However, as indicated by ISEG Observation Report ST-HS-P2-157, not all personnel were consistently documenting station problems when found. Thus, this critical mechanism for early identification and documentation of problems may not be implemented effectively.
The plant management was asked to ' address the ISEG report conclusions in its connitments to this inspection.
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, The following. recommendations were communicated to applicant representatives and will be reviewed.at'a later date: (1) Plant, systems' engineers and operations. staff-should' review the draft NUREG 1275 report for lessons learned to avoid unplanned reactor trips and ESF actuations and'should.
specifically consider the lessons learned from other-similar,.recently-licensed operating reactors for: improvements to the startup' testing program, procedures, setpoints, and design that might help avoid early startup problems.during the period that the plant staff is developing familiarity with the' equipment and experience in operating the plant and the procedures and systems are '. being " debugged;" (2) Lines of~ communication'should be established with other recently-licensed PWRs..to obtain an earlier indication of.- operational problems.and the possible corrective actions.
- This..will assure more tinely corrective action than that which might be available by dependence on INP0 screening of
, individual plant LERs.
No violations or deviations were identified, l 10. Qualified Display Processing System'(QDPS)
The QDPS. is a new one-of-a-kind system used at STP. This distributed l microprocessor based system was audited by' the staff to verify implementation and to assess its operational effectiveness. This inspection focused on the adequacy.of operating controls and operator i interface, and was accomplished by reviewing programs and procedures, interviewing personnel, touring the facility and observing ongoing activities.. Particular emphasis was placed on operator interface with the QDPS.
a.
Controls Over Operation After construction and installation the QDPS was turned over to the startup organization, in May 1986, at which time the QDPS was energized. As part of the QDPS checkout, startup field reports (SFR) were used to docurnent discrepancies from the operational test requirements. These SFRs were sent back to engineering for evaluation and approximately 95 percent of the reports were sent to Westinghouse for resolution. Westinghouse would then issue a change package which would contain replacement PROMS and field change notices (FCNs). All FCNs wou'ld contain: (1) instruction for installation, (2) identification of location for each PROM by code number and revision level, and (3) a functional description of the changes to
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_ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ - _ _ _ ! l-38 aid in identifying retest requirements. Bechtel then reviewed the FCN and issued a Change Control Package (CCP). A significant portion of the inspection effort was spent reviewing documents within this process. Most discrepancies fell into three categories: (1) out of tolerance, (2) software design changes (i.e., display readings were either high or low compared to incoming signals, and (3) hardware < changes (bad components on cards).. Once the system was turned over to operations, hardware and software changes were recommended by engineering support request (ESR) under HL&P operations and QA program. Operations would generate a ! maintenance work request (MWR) and the I&C technicians would perform the work in accordance with their governing procedures.
For example, as a result of the control room design review (CRDR) approximately 80 sof tware changes were. recommended to update the displays. All software changes were to be made by Westinghouse in accordance with , the staff approved Verification and Validation (V&V) program.
Then the PROMS were to be updated and Westinghouse would issue a FCN.
The only major hardware change to the system was the DC-to-DC converter card. During startup and preoperational testing this card experienced a number of failures which were attributed to bad components. Westinghouse is in the process of replacing all 24 DC-to-DC converter cards within the QDPS.
For the period of the past nine months, the QDPS hardware has demonstrated a high reliability.
Installation.of all QDPS modification packages were approved by ' management. The documentation program used for tracking all modifications evolving from SFR, ES, FCN, and CCP through implementation appeared to be very thorough and complete.
b.
Operation Interface With ODPS As part of this inspection, the NRC inspectors observed control room activities using the QDPS. The system had been in operation for nine months and was used extensively by the operators for bringing other systems on line. The operators had received both classroom and simulator training on the QDPS. Observations and discussions with the operators indicated an overall understanding of each display and an ability to call up new displays to support timely response to new alarms. Overall, the STP operating staff was well informed, knowledgeable in the operation and execution of the QDPS: (1) protection, (2) qualified control, and (3) post-accident monitoring.
In terms of readiness for operation, no major impediments to the QDPS design and implementation were identified. The applicant had
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L _ v , ' ' demonstrated adequate management.of the QDPS design, construction,. testing, and installation.
In summary, the QDPS 'at the $TP was c deemed to be ready for. operation.
No violations or deviations were identified.
11. Master Completion List'(MCL) Review ' The NRC inspectors reviewed the MCL. The purpose of the review was'to verify'that items on the MCL had been assigned justifiable completion milestones.
The milestones were points before which the item was to be completed and closed. -The MCL had two major sections.. One was items assigned to specific systems, the other items were assigned to physical' areas.. In the systems portion of the review, 53 systems were reviewed which included safety-related systems and subsystems and TS-related items. The 53 systems. included approximately 400 separate items. The NRC inspector.- .found 10 items which the licensee agreed should have been given different milestones..Two of those were apparent typographical errors..The entries.
' did.not: correspond to defined milestones.
Two items'were new entries and milestones'had not been assigned. Two-items appeared to be' entered in . error. The MCL did not 11st a' source document. The licensee stated that ~ they wanted to close those items, but were reluctant to close them without source-documentation on which to record resolution. The remaining 4 items appeared to have had too late of a milestone assigned. The systems.
~ engineers. agreed and the licensee stated that these 4 items, as well as the other 6 milestones, would be revised.
In the physical area portion of the review, the NRC inspector examined approximately 390 line items. The NRC inspector was in disagreement with 6 of the assigned milestones. They involved: Installation of. cover plates on the-control room floor drains - Grounding of some nonsafety cable in the auxiliary building Revision of a grating platform to clear a safety-related heating ~ ventilation and air conditioning (HVAC) plenum Removal of sufficient. insulation to allow ease of operation of a
nonsafety steam valve- . Installation of-flashing at moisture separator reheater pipes at a turbine. generator building (TGB) penetration Modification of supports'on a nonsafety demineralized to reduce
vibration - _-.
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, All of the above were assignhd post-initial cri.ticality or. power operations milestones. The line items were discussed with the Nuclear Construction Services. Group; General Supervisor and their completion milestones were changed to either initial criticality.or power operations as' appropriate.. .The NRC inspector noted that the major.ity of the remaining items were appropriately designated for completion prior to initial criticality. The inspector' remarked that the volume of work would prov.ide for an ambitious schedule between fuel. loading and criticality.
No violations or deviations were identified.
12. Management' Exit Meeting An exit meeting was conducted _at.the STP site on July 2, 1987. The applicant representatives present at the exit meeting are identified in Appendix B.. The' scope cf.the inspection and the inspection findings were discussed. The applicant was informed that the open items which are referred to.in the report as observations.would have to be resolved or-dispositioned prior to the licensing decision.
The applicant was informed' that they should provide'the NRC with a letter which would provide their.
commitment for the resolution or. disposition of each observation and the-milestone by which the action'will be complete.
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. _____-__________ - APPENDIX B Persons Contacted The following is a, list of persons who attended the exit meeting on
- f July 3, 1987.
J. Goldberg G. Parkley M. Ludwig D. Bednarczyk T. Underwood R. Cook J. Green G. Ondriska G. Jarvela T. Reis D. Cody T. Sobey J. Loesch S. Head C. Ayala F. White R. Chewning M. Harot D. Hooper M. Wisenburg T. Puckett J. Geiger I. Guthrie A. Hill C. Kern J. Westermeier S. Dew W. Kinsey G. Vaughn l l ~ . $
' ' Enclosure 3 L' The Light company P. O. Box 1700 Houston, Texas 77001 (71M 228-9211 Houston Lighting & Power.. July 15, 1987 SI-HL-AE-2298 File No.: C20 , 10CFR50 $ @ b b k! U. S. Nuclear Regulatory Commission Attention: Document Control Desk i Washington, DC 20555 JUL 2 0198( ! South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Observations of the NRC Operational Readiness Review Team The NRC performed an Operational Readiness Review at The South Texas Project Unit 1 (STP-1) during the week of June 29, 1987. Based on statements made by the NRC team at the exit meeting, we understand that NRC found that Houston Lighting & Power Company is ready to operate STP-1.
Observations made by the NRC in the course of the review and HL&P's responses to these observations are summarized in Attachment 1.
The actions to be completed prior to fuel loading have been completed.
If you should have any questions on this matter, please contact Mr.
S. M. Head at (512) 972-8392.
. J. H. Goldberg Group Vice President, Nuclear SMH/hg Attachment: Response to Observations of the NRC Operational Readiness Review Team L4/NRC/qr/hg-0 A Division of Houston Industries Incorporated )9- \\\\( <9 'a a inrn o D I b \\V)[[ - _ _ _ _ i
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._ . _ _ , ' l Attschment l FT-HL AE-2298 ' Flie No.. G20 Page 1 of 10 Attachment Responses to NRC Observations Made During The Operational Readiness Review (June, 1987), . ' Observation #1 The NRC viewed a number of video tapes shown to HILP.
personnel which discussed the transition phase to an o3.e ating plant and summarized the experience of other recently lic-need plants.
It was noted that only NPOD personnel had been provided the opportunity to view these tapes.
Response: STP personnel in the Independent Safety Engineering Group (ISEG), Qualitj Assurance (QA), Licensing and Engineering groups will be provided the opportunity to view these tnpes prior to initial criticality.
Observation #2 The NRC reviewed the training that has occurred ca 10CT*150.5) Safety evaluations and noted that additional personnel potentially involved in 10CFR50.59 safety evaluations need te be trained.
Response: Additional personnel who may be involved in preparing or reviewing 10CFR50.59 safety evaluations will be trained before initial criticality.
Observation #3 Plant personnel that could be involved in preparing and ' reviewing Licensee Event Reports need to be trained. Training should focus on generic implications and root cause evaluations.
Response: Personnel who are expected to be involved in the preparation and review of Licensee Event Reports will be trained by initial criticality. Generic implications and root cause evaluation will be specifically addressed.
. g Observation $4 The Work Control Center (WCC) should be subject to overview l by other onsite groups such as ISEG and QA.
Response: QA recently performed a review of the WCC and changes based on recommendations from these activities are in process. WCC activities are currently included in maintenance audit plans.
In addition, ISEG will be conducting an observation of WCC activities in the near future.
i Observation #5 A program should be developed to identify plant equipment which j may contribute to spurious plant trips or safeguards activations if not adequately posted or protected.
Response: A review team will be formed to review the plant design for ' sensitive equipment and to make recommendations for providing physical protection or warning signs. This review will be , completed prior to initial criticality and priorities will be set for implementation of any appropriate protective actions.
L4/NRC/qr.
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. .Dbservat!mn e6 \\fhe need to p krform ' 9dcitional, testing or unique plant desigt\\ 4-
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features soul'dghe;n aluated.
.h , ' ~ ) Response HLAP's believes that unkie features of the STP design' F have been adequately add $ssed in the start-up test. pro /ces y .%" f , -fi ~
(described in the FSAR and SER). However, a teams wi1F 1e l (\\ formed with representatives fpm Eng'incering, Starts /, a' W,,.P n l' - Nu: lear Plant Operations that will review the uniqus '/esijtn / features of the p1mt: and will reevaluate the adequacy of t,71 ' current test.prograss. This u aluation will be complete p 'tir h., to icitial criticality.. Any additional testingUound tkbe / t ' F P }'l' ' Appropriate will be performed at. the' appropriate best plateau L T In thel ppver ascension tepr?.ng program.
b, s . I' ' . y y ,
a . j; ? - observation e WLAPAhould ' reassess the cuc ent stsffing level of IpG;boed , , 'I ~ t.h tLe activities and scope' of work planned for that group'. I
,
AlthoughISEGebtaffings;sincompliancewiththecurpntdraft Response ( c j echnical Spedificatis.ni,.,ISEC is continually reassear.#ing,.t1/4 < g ,' '" / resource requirements c& ta group.
Present plans call fo't '. ; ' i utilizing experiences (ptuaanel from outside the company if \\ ! augr.enting the group pebnes necessary. This allows the , maxiinum flexibility for the group during'the initial (phases of operation. As lont;.iers workload becomes more defined IMG
will ensure that niequate resources are available to perfo y - y the functi m assijlned to> the group.
, p , , i observation.<8 Training perbonnel thould\\;ontinue to maintain a current G i L understapiing of plant operations through involvesist in plant j , 7 (, 4; operatets., -
, f' - s j , ' t .. , Resp $ hse: Instructbra f a are licensed SRO's are currently meeting tb- ! requiro63ncs of the ERC-approved License Requalification ' > , Program of at least three 8-hour shif';s/qtr.., Altonativente under c.pnsideration to increase instructor time ir.y.he plant.
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Obs'ervation #9 H14P should evaluate the need for covers over sensQ' 'ive $ switches on the main control panel.
y-l Er s [n Response: A similar observation was recently made dujinj; the Project ' / Review team walkdown portion of the Cop:;rolhom Design Review, . y J sd is being brought to the, attentior.' of the Control F.oom ,
- Disign Review Management R@lew Team (i?T).
It is anticipated . that the MRT review will be completed sud any appropriate hetjess taken prior to December 1, 1987, ' ,. Y \\ [ t , .. .y 't $ h' ' f_ e, y i ' s L (I
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, - .-- ' L' , i ) - Attachment ' .. ' ST-HL-AE-2298 File No.. G20 { Page 3 of 10 l , Mrvation elC ' Tnere appears to be f ri. tion lictween the Operations and Training staffs of the plar.t.
. Response: ' HLAY< Management has takwn a number of actions over the past six months to elimincte friccion bstvean Operations' and Training personnel. These actiers have reduced the level of friction, and it is antici, aced that the residual level of l , friction will continue to subnide. HL&P management is developing a plan for rotating peraor. del between these two departments to previde creas training and a better mutual understanding of each departaont's activities and responsibilities. HL&P ranagement will continue to monitor this situation.
Observation all Licensed Operators have received only one week of simulator training this calendar year.
Response: Licensed Opera' ors are currets:1y scheduled for an additional week of simulator training starting the week of July 13, 1987 as part of the requalification program. HL&P management will continually evaluate the need for additionai simulator s s training bnsed on operator performance.
, Observation #12 Simuletor,t*caining should include simulation of actual industry operating events.
Response: SIsulator training for licensed operators hts been conducted on selecte6 industry operating events at appropriate points iii the licenne craining curriculum. Events specifically addressed include: o Steam Generator Tube Rupture. Ginna o ATWS - Salem o ' Pressurizer PORV Stuck Open - TMI o RHR Water Hamer - STF ~ Industry Operating Events are reviewed by the Training Department. When a training need is identified, action is taken to provide the necessa':y training.
Significant differences in plaat designs often precludr. detailed simulator training on industry operating events.
V ' '( lA/NRC/qr.
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, _ _ - - __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ . Attechm nt ST-HL-AE 2298 File No.. G20 Page 4 of 10 HL&P will continue developing action plans for training operators based on industry operating events, and emphasis shall be given to utilizing simulator training where , possible.
Observation #13 Improvement is needed in drawing control for the control room and auxiliary operators.
Response: Shift administrative aides have recently been assigned to support the control room operators in administrative duties.
Part of their shift check lists include removing outdated working copics from the control room files.
In addition, the flat drawing files in the control room will be removed and replaced with stick type files which will be spot checked each shift by the shift administrative aide to ensure none of the stick files are misplaced or missing.
In addition, the aides will also be responsible for keeping working copies of drawings for plant operators up to date.
Observation #14 HL&P should consider adding an Limiting Condition for Operation (LCO) status board in the control room.
Response: Current procedures provide for LCO's to be entered on a log sheet.
Since the LCO log sheet may not be visible to the other licensed operators in the control room, HL&P will also require entries in the Unit Supervisor and control room logs of entry into an LCO and exit from an LCO. Additionally licensed personnel will be required to review the "Out of Service" Log as part of shift relief. These requirements will be implemented prior to fuel load.
HL&P has previously evaluated the need for a LCO status board in the control room. HL&P believes the system noted above will provide for an adequate assessment of current LCO ' conditions.
It should be noted that a status board becomes an additional administration burden to control room personnel that at times of rapidly evolving plant conditions could fall behind plant conditions.
Observation #15 Equipment clearances were logged sequentially and not by system. This process should be re-evaluated.
Response: Although equipment clearar.ces are not cataloged by system, each clearance has a designator for the system. Since a high percentage of clearances ultimately affect components of more than one system it is difficult to isolate clearances by system. While there would be soae advantage to cataloguing by system, there would also be disadvantages. HL&P believes that changing the process would not result in a better understanding of component or system status by the operator.
However, we will continue to evaluate this program and will effect changes if they appear to be required. Currently, L4/NRC/qr.
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ i Attachment ST-HL-AE-2298 File No.: G20 Page 5 of 10 HL&P is pursuing the implementation of a computerized LCO tracking system.
This system will allow for a rapid assessment of all equipment clearances on a sfstem wide basis.
Observation #16 HL&P should re-assess the frequency of plant walkdown by the plant operating staff.
Response: Currently, plant and system surveillance are performed once per shift by Reactor Plant Operators and Shift Supervisors and documented in the " Plant Operator Round Sheets" for each operating position. HL&P will continue to evaluate the adequacy of this schedule and will make changes as appropriate.
Observation #17 There is a possibility of cable damage due to personnel entry into the cable bridge storage vault.
Response: HL&P will administratively restrict entry into this area by posting warning signs to minimize the possibility of damage.
Observation #18 While the overall cleanliness is good, it appears that hard to get at places still need additional cleaning effort.
Response: Plant management plans to re-perform a walkdown of the plant to ensure we have established an appropriate level of cleanliness prior to fuel load.
Observation #19 Improvement is needed in the training on feedwater control at low power levels, specifically as it relates to the transition between the use of the motor driven Start-up, feed pump and the turbine driven feed pumps.
Response: Cold Licensed Operators were trained in the classroom on the Feedwater Control System and the Cold License simulator training included manipulation of the Feedwater System in manual and automatic control during startups, shutdowns, normal operation and feedwater malfunction conditions.
Classroom training specifically included the operation of the Start-up feed pump. However, during this phase of training, the Start-up feed pump controls were not on the simulator.
The simulator now includes these controls.
Requalification training of Licensed Operators includes simulator training on feedwater control during startup, shutdown and casualty, with feedwater controls in manual and automatic. The first week of simulator training for Licensed Operator requalification was completed on July 3,1987 and the second week is currently scheduled from July 13 through August 14, 1987. As actual plant feedwater control characteristics are determined, this information will be factored into operator simulator and classroom training.
L4/NRC/qr.
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_ _ _ _ Attachment ST-HL-AE 2298 File No.: G20 Page 6 of 10 Observation w20 The processing and investigating of anonymous tips related to drug use does not appear to be consistent.
Response: Nuclear Group Policy " Fitness For Duty" was revised on July 6, 1987.
It now stipulates specific consistent actions - to be taken when anonymous tips related to drug use are received.
SAFETEAM procedures have been revised and the SAFETEAM interviewers instructed to encourage anonymous persons to reveal their identity in order to provide HL&P a greater opportunity for an effective investigation.
Observation #21 The processing of additional concerns brought to the attention of a SAFETEAM investigator during the conduct of investigations appeared inconsistent.
Response: The appropriate SAFETEAM procedure has been revised to ' specify how SAFETEAM investigators are to process additional concerns brought to their attention during the conduct of investigations, and investigators have been trained to the revised procedure.
Additionally, individual meetings were held with each investigator to determine if any additional concerns had been brought to their attention which might not have been addressed by SAFETEAM. As a result of these interviews, two such concerns were identified. Although not considered safety significant, these concerns are currently under investigation by SAFETEAM. Completion of this investigation is expected by July 31, 1987.
Observation #22 The SAFETEAM Program Director reviews all concerns received by SAFETEAM and assigns the classification.
Classifications are Class 1 Nuclear Safety or Quality, Class 2 Management, Class 3 Industrial Safety, Class 4 Security, and Class 5 Miscellaneous. All Class 1 concerns are investigated by SAFETEAM and Classes 2 through 5 are normally assigned to other organizations. The Director may, however, assign selected Class 2 through 5 concerns to SAFETEAM for investigation.
The NRC identified two concerns: 1) there was no independent verification of the classification process, and 2) two Class 2 concerns were identified which appeared to be of a nature that they should have been classified as Class 1.
Response: An independent review of the classification of new concerns will be performed by the General Manager, Nuclear Assurance.
This process has been instituted, effective July 3, 1987.
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Attachment ST-HL-AE-2298 i File No.: G20 ) Page 7 of 10 A review of the classification of concerns received by SAFETEAM prior to July 3, 1987 has been conducted by the General Manager, Nuclear Assurance. As a result of this review one of the two classifications of concerns identified by the NRC as questionable was reclassified to Class 1 and is - being investigated by SAFETEAM. This evaluation will be , completed by July 31, 1987. An additional 16 concerns (from a total of 1161) were identified which should have-been classified as Class 1.
However, review of the response letters for the 15 of the 16 for which the investi ation was
complete determined that the concerns had been properly addressed.
The remaining one of the 16 was reclassified to. Class 1 ar.d is being investigated by SAFETEAM. This investigation is also scheduled to be completed by July 31, 1987.
Observation #23 For significant concerns which have been substantiated by SAFETEAM, the records do not consistently reflect that a review has been conducted to assure that, as appropriate, root cause(s) have been identified, generic implications assessed, and appropriate corrective action taken.
Response: In response to this observation significant substantiated concerns have been reviewed by a team of two QA specialists headed by a Project QA Supervisor. For each concern, root cause was identified, generic implications assessed, and corrective action taken. The review identified cases where additional actions and documentation are required. However, in no case did the review identify any substantive issue that requires resolution prior to fuel load, Appropriate corrective actions will be completed by August 15, 1987.
Observation #24 The method of cross referencing surveillance procedures to other affected Technical Specifications should be improved.
Based on the inspector's observation that this item should Response: be considered as an enhancement to the existing program, surveillance procedures will be reviewed and revised as necessary to ensure that all affected Technical Specifications are referenced. This effort will be completed prior to the end of full power testing.
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Attachment " ST-HL AE-2298 File No.: C20 Page 8'of 10 l ' Observation e25 --HIAP is - requested to address the need to verify valve j position during surveillance testing for those valves that do not have direct: positive indication of valve position.
' Response: Although the STP methods-for determining valve position are ! consistent.with current industry practice, an evaluation will be performed prior to initial criticality to determine those ' valves which do not have positive indication of valve position on' safety related. systems. After the evaluation is complete, alternative methods of positive valve position / verification.will be assessed.
Observation #26 'The Surveillance Index did not reference the partial stroke test procedure for Main Steam Isolation Valves as a requirement to satisfy Technical Specification 4.7.1.5. Are 'there any other such omissions in the Surveillance Index? Response: Technical Specification 4.7.1.5 references Technical Specification 4.0.5.
The Surveillance Index entry for 4.7.1.5 listed the full stroke test procedure which is performed.in modes 5 and 6.
The Surveillance Index entry for 4.0.5 listed the partial stroke test procedure which is performed in modes 1 through 4.
In order to resolve this ites, the entry for 4.7.1.5 has been revised to list both procedures.
In addition, the complete index has been . reviewed for other similar occurrences and none were found.
Observation e27 In its review of the application of torque and limit switches on motor operated valves, the NRC review team noted that it is unfamiliar with the use of bypass switches to inhibit the function of-torque switches for most of the valve ~ disc-travel.
Response: The basis for this control concept is to ensure that torque switches do not prevent the opening or closing of safety related valves. This concept vss addressed in HIAP's response to IEB 85 03, " Motor g erated valve Common Mode Failures During Transients Due To Improper Switch Settings" which has been reviewed by Region IV personnel.
Observation #28 Torque and limit switch setpoints for Motor Operated Valves are not readily available for use by craft personnel in the field.
, Response: Bechtel Engineering has recently issued a MOV data base document which is currently under review by HIAP. This document specifies both torque'and limit switch settings for all safety-related MOV's.
This document will be issued to the Operations Document Control Center for field use by , July 31, 1987.
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Attachment ST-HL-AE-2298 File No.: C20 I Page 9 of 10 Observation #29 Torque switch settings on BOP valves appear to be set on minimum values. This setting philosophy could cause unnecessary transients.
" Response : Torque switch settings on BOP valves have been set according to vendor instruction or per requirements established during preoperational testing.
Observation #30 Some electrical maintenance personnel did not obtain on-the-job training (0JT) during the preoperational phase of testing.
Response: The Maintenance Department has an ongoing interim OJT program for technicians. The adequacy of the program will be reassessed by October 31, 1987. Training received during the preoperational phase of testing will be specifically considered.
The finalized OJT program is scheduled to be in place by December 1, 1988.
Observation #31 Some electricians did not have the opportunity to be involved in the development of maintenance procedures or subsequent procedural walkdowns and as such missed out on a valuable training opportunity.
Response: HL&P agrees that procedural development is a good training tool. However, scheduling and manpower constraints prevented involvement of all technicians with procedural development.
Normal maintenance technician development, as supplemented by OJT and formal classroom training, will ensure that technicians are trained adequately for the performance of their activities.
Observation #32 There may be a need for improved training of electricians regarding safe methods of trouble shooting on batteries and inverters.
- Response: See response to observation #30.
This reassessment will also include trouble shooting on batteries and inverters, specifically in regard to safety of electricians.
Observation #33 What is HL&P's intended action as a result of the ISEG observations on Reactor Operator rounds and shift turnover.
i Response: The Plant Operations Department is developing a training session for the Reactor Plant Operators to be presented by Plant Operations Management by July 31, 1987. Within this presentation specific guidance will be provided on expected operator conduct during performance of their rounds.
In addition, Plant Operations management will provide on-shif t training to Reactor Plant Operators prior to July 31, 1987.
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. . -9 l Attachment ST-HL AE-2298 File No.: G20 Page.10 of 10 Observation #34 What is HL&P's intended action as a result of.the ISEG assessmentonmanualvalvereachrodconcerns} JRe sponse.: In response to the ISEG assessment the Plant Operations Department developed a list of manual reach rod valves and physically tested the operability of those reach rods installed. Maintenance work' requests have been submitted on inoperable manual valves. Rework on inoperable valves has been completed.
Future installation of valve reach rods will require a post installation operability test as part of the work package.
Observation #35 How will reports generated by ISEG be addressed by the plant.
staff? Response: A procedure will be written which specifies actions to be taken as a result of ISEG reports.
This procedure will be completed by September 30, 1987. As an interim measure, plant management has directed that responses for ISEG reports be generated by responsible managers which address pertinent issues identified in the report.
Observation #36 There were 12 open SAFETEAM concern investigations reviewed by the NRC for which sufficient information was not yet available to determine if these concerns could affect fuel load.
Response: The investigation into 6 of the 12 concerns identified by the inspector have been completed by SAFETEAM. The remaining concerns have been evaluated and it has been determined that, even if substantiated, they would have no impact on fuel load.
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- , l . Enclosure 4 . G o The Light l Company n,~,,,, ueio,w <,m m n<,um, n<,im >,,.wm mium> 22 pen August 18, 1987 ST-HL-AE-2328
File No.: G9.15. S9 10CFR50 @hbONk U. S. Nuclear Regulatory Commission NE 2 0 B87 ' Document Control Desk Jjt Washington, DC 20555 y . Ref (1) letter J. H. Goldberg Same subject dated 7/15/87 ST-HL-AE-2298 I Ref 1 provided H14P's responses to the observations made by the NRC during the conduct of their Operational Readiness Review of STP Unit 1.
Based upon conversations with Hr. J. Gagliardo, we are providing additional information in Attachment #1.
If you should have any questions in this matter, please contact Mr. J. E. Geiger at (512)972-8620.
.k J. H. Goldberg Group Vice President, Nuclear JEG/sd Attachment %] d N n mi e ,,,, . m iupvivaut f- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
_ _ _ _. _. - _ _ _ _ _ _ _ _ _. - _ _ _ __ _ ___ _ _ _ _- _ _ _ , ! , !. t.d : Attachment I % The' response to Observation #20 is revised to read as follows: OBSERVATION #20'- The processing and investigating of anonymous tips related to ' drug use does not. appear to be consistent.
Response: The Nuclear Group. Policy " Fitness For Duty" was' revised on July 6, 1987.
It now stipulates specific consistent actions to
be taken when anonymous tips are received; viz, o Report incident to HL&P Security Department.
o The report shall be documented on a " Telephone / Walk-In Tips Form."
o The HL&P Security Department shall instruct appropriate supervision to conduct a behavioral observation of the' individual for 30 days and immediately report any aberrant ' behavior.
Supervisors 'shall complete the Employee Observation Report- -o and forward to the Security. Department.
In addition NSD will contact local law enforcement officials concerning the subject of the anonymous tip.
' The SAFETEAM procedure has been~ revised and the SAFETEAM interviewers instructed to encourage anonymous persons to reveal their identity in order to provide HL&P a greater oppor-tunity for.an effective investigation.
The applicable procedure now reads: ... the interviewer should attempt to encourage the " individual to come forward with his/her name. The individual should be made aware that the action HL&P can take. in response to anonymous drug concerns-is limited unless the individual is willing to come forward."
The ensuing paragraph in the procedure has not been revised, and currently reads: "If the individual insists in remaining anonymous, the interviewer should ensure that they have solici-ted as much information as possible. " .. To guide the interviewer in soliciting information, the existing SAFETEAM Reference Manual contains a list of questions to be asked involving who, what, where, and when.
The NSD Investigations personnel who are the other group most likely to receive anonymous drug tips have been reminded to continue to attempt to convince people who provide drug tips to identify themselves.
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