IR 05000498/1988006

Insp Repts 50-498/88-06 & 50-499/88-06 on 880105-15 & 26-29. No Violations Noted.Major Areas Inspected:Lers,Written Repts Performed in Region IV & at Unit 1 Site

ML20150D221
Person / Time
Site:	South Texas
Issue date:	03/11/1988
From:	Robert Evans, Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20150D214	List: IR 05000498/1988006 ML20150D210
References
50-498-88-06, 50-498-88-6, 50-499-88-06, 50-499-88-6, NUDOCS 8803230203
Download: ML20150D221 (9)

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APPENDIX- '

U.S.-NUCLEAR REGULATORY' COMMISSION

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REGION IV

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NRC Inspection Report: 50-498/88-06 - ' Operating License: NPF-71 50-499/88-06 Construct, ion Permit: CPPR-129 Dockets: -50-498

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50-t99 Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project (STP), Unit 1 l

Inspection At: U.S. NRC Region IV Office, Arlington, Texas, and STP-1 site, Bay City, Texas Inspection Conducted: . January 5-15, 1988, in the RIV office and January 26-29, 1988, at STP site Inspectors: ./mf 4 Th\ 9 2 R-88 R. J. Evans, Reactor Inspector, Operational Date Programs Section, Division of Reactor Safety 7 88>

D. R. Hunter, Chief, Technical Support Staff Date Divis on of Reactor Projects Approved By: \b

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Z\E. Gagiardo, Chief, Operational Programs

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Section, Division of Reactor Safety Inspection Summary Inspection Conducted January 5-15 and 26-29, 1988 (Report 50-498/88-06; 50-499/88-06)

Areas Inspected: A special inspection of selected South Texas Project Electric Generating Station Unit 1 (STP-1) Licensee Events Reports (LERs), written reports, was performed in the Region IV office and at the STP-1 sit PDR ADOCK 05000498 O DCD

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Results: Two of the written reports reviewed-(LER 87-12, paragraph 2.a.1) and LER 87-17, paragraph 2.b.1) - described events considered as significant by the NR The additional details on LER 87-17 are documented in NRC Inspection Report 50-498/87-71. Both the matters were discussed with the licensee during an enforcement conference conducted on December 30, 198 t

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DETAILS

. 1.- Persons Contacted HL&P

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R. Beavers, RMS Supervisor J. Bouton,. Licensing Engineer C. Ayala, Supervising Licensing Engineer R. Ferguson, Licensing Engineer

• D. Phillips, Engineer-

• J. S. Phelps, Supervising Engineer

• G. E. Vaughn, Vice President, Operations

• T. J. Jordan, Project QA Manager

^J. T. Westermeier, Project Manager

• J. E. Geiger, Nuclear Assurance Manager

• S. M. Head, Supervisor, Operations Licensing

• H. E._Dudley, Nuclear Training Supervisor

• M. A. Mc8urnett, Operations Support Licensing Manager NRC H. F. Bundy, Project Engineer G. L. Constable, Chief, Project Section D

• R. J. Evans, Reactor Inspector D. R. Hunter, Chief, fechnical Support Staff

• D. M. Hunnicutt, Senior Project-Engineer

• A. B. Beach, Deputy Director, Division of Reactor Projects

• J. P. Jaudon, Deputy Director, Division of Reactor Safety

• Denotes those attending the exit intervie . Area Inspected (In-Office Review of LERs)

The Licensee Event Reports (LERs)_87-01 through 87-25 were reviewed to determine whether the LERs described any specific or generic operational safety problems. The reports were generally accurate and of accaptable quality. Two of the LERs (87-01 and 87-08) were determined by the licensee to describe nonreportable events. The LERs reviewed involved personnel errors, surveillance procedure deficiencies, and the Toxic Gas Monitoring Syste Personnel Errors The review of STP-1 Licensee Event Reports (LER) identified four LERs resulting from operator error (87-01, 87-04, 87-05, 87-12), and four LERs resulting from nonoperations personnel errors (87-06, 87-13, 87-22, and 87-24). Two additional LERs, 87-02 and 87-15, identify possible switch / controls manipulation without the knowledge or concurrence of operations personnel. The inspectors also noted two

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.LERs (87-21 and 87-25) which had root causes that were not conclusively identified, but were associated with personnel erro The following weaknesses were identified from the LERs reviewed:

(1) LER 87-12 reported the operator error that led to the High Head Safety Injection (HHSI) System being declared inoperable due to the cold leg injection valves being closed while in Mode Illuminated alarms were not recognized or responded to properly, and the operators failed to recognize that the valves had been closed for 51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br />. This described situation indicated a lack of attention by operations personnel to the control board lineup and a failure of the operations staff to identify alarms that were valid for the mode of operation. The closing of these valves is significan_t because Technical Specifications (TS),

Section 3.5.3.1.c requires that two of the three HHSI valves be open while in Mode 4. This matter was discussed with HL&P management in an enforcement conference conducted on December 30, 1987, in Region I (2) LER 87-05 described a control room ventilation actuation to recirculation mode (ESF actuation) due to a loss of power to the toxic gas monitors. The power loss was due to personnel error, followed by an incorrect operator response to a local inverter alarm. There was no indication in LER 87-05 whether or not the operator used the procedure to respond to the local alarm or to line up the inverte (3) LER 87-25 described a loss of offsite power event. Although the root cause could not be conclusively established, the event appeared to be the result of the failure of maintenance personnel to follow written procedures verbati The number of LERs associated with operations / personnel errors indicates a need for continued training in the use of procedures in the areas of plant operations and maintenance at STP. Use of procedures during alarm respo' as also should be stresse Observation of correct procedures used should be considered by HL&P management. The control and verification of plant status at all times, but particularly during mode changes, should be evaluated extensively by HL&P managemen Surveillance Procedure Deficiencies Three LERs (87-09, 87-17, and 87-19) were the result of surveillance L procedure deficiencie The following weaknesses were identified:

(1) LER 87-17 described the event where the pressurizer low pressure SI setpoint was found to be low (setpoints less conservative

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than TS requirements) due to surveillance procedural error The LER 87-17 stated, ". . . No violations of the Technical Specifications occurred." ThezTS sections quoted were 3.3.2 and Table ~3.3-3. The pressurizer pressure-low instrumentation is required to be operable in Modes 1-3 with a footnote on Mode 3:

"Trip function may be blocked in this mode below the'P-11 (Pressurizer Pressure Interlock)'setpoint." The NRC staff considers the pressurizer low pressure channels to have been inoperable due to setpoint errors; therefore, the applicability of the footnote does not appear to-be relevant to the

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operability issue as applied by the licensee in LER 87-17. An apparst violation of TS violation, Section 3.3.2, occurred due

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to the instrumentation channels being inoperable during Mode 3 operation on November 22, 1987. .This matter was discussed with

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HL&P management in an enforcement conference conducted on Decerrber 30, 1987, in Region IV (Reference: NRC Inspection-l Repert.No. 50-498/87-71).

(2) LER 87-09 documents an event that was the result of a procedure not being_ updated when the TS were revised. The licensee needs

.to implement measures that ensure changes to the license, or TS,

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are reflected as appropriate in the program and procedure The failure to ensure procedures were updated / correct following a change to the TS appears to be the root cause of these events. The controls established to provide program and procedure changes when appropriate should be reviewed by HL&P management. .In addition, the interpretation of the TS by HL&P in LER 87-17 was not acceptable, Toxic Gas Monitoring System Seven LERs involved the Toxic Gas Monitoring System, including a loss of power (87-05, 87-13), equipment failure (87-07, 87-11, 87-20),

detection of paint fumes (87-14), and inoperability following a channel check (87-22). LER 87-20 indicated corrective action which included modification (two inoperable monitors on loss of power or malfunction to initiate an ESF actuation) to the Toxic Gas Monitoring System. The purpose of this modification was to reduce the number of Engineered Safety Feature actuations and subsequent LERs due to a single monitor failur The high number of LERs associated with the Toxic Gas Monitoring System indicates that a review of the design may be in order to reduce unnecessary actuation, thus preventing premature wear and damage to the control room ventilation equipmen . Areas Inspected (0nsite Followup of LERs)

To supplement the in-office review of LERs, an onsite followup was performe Three LER/ Station Problem Report (SPR) packages were inspected onsit All three (LERs 87-01, -06, and -07) had been closed by the

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licensee. The. corrective actions to four LERs were inspected in the field to verify completion (LERs 87-01, -04, -14, and -24). Additionally, requests for additional informa', ion on five other LERs were directed to STP Licensing Engineering Group by the NRC (LERs 87-02, -06, -12, -15, and-20).

The details of the inspection are described below by LER numbe i LER 87-01 The corrective actions and completed LER/SPR package of LER 87-01 were inspected. The panel Rm-11 displays were observed with no concerns. The SPR package No. 870337 was inspected to verify LER closecut. The LER event date was August 24, 1987, and the LER closecut date was January 23, 1988. The lack of timeliness on closecut of the LER was noted. NRC closecut of LER 87-01 is not required since this LER is considered "voluntary." LER 87-02 A request was mada to inspect local radiation monitor skids to verify completion of corrective actions. The licensee stated that corrective actions a through c may be revised since the original corrective actions were rejacted during an engineering revie Because of the possibility of an LER 87-02 revision, the field verification was not attempted. LER 87-02 is ope LER 87-0 The corrective actions of LER 87-04 were field inspecte Panel ZCP-023 was inspected, with one incomplete action note Corrective Action Item No. 4, the placement of red warning tape on the panel, was not completed. A licensee representative stated that the tape was placed, then removed, from the panel at a later dat The NRC inspector determined that the tape was not necessary since corrective action item No. 3 placed warning labels on the panel which performs the same function as the red tape. LER 87-04 is open, LER 87-06 The root causes and corrective actions of LER 87-06 were inspecte As stated in the LER, the cause of the event was the use of the wrong procedure by a technician while changing a filter on the radiation monitoring system. The corrective actions consisted of technician training. The cause of the event was a technician using the wronn procedure but the root cause may have been inadequate supervision, improper training or any similar programmatic error _ . . . _

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The corrective actions stated in LER 87-06 were verified complete by the NR The LER 87-06 (SPR No. 870356) event date was September 5,

. 1987, corrective actions were completed on September 23, 1987, but closure date by licensee was January 28, 1988. This event report is considered closa LER 87-07 .

I A review of the LER/SPR No. 870359 package was performed. The LER 87-07 was closed by the licensee on January.3, 1988. The event date was September 6, 1987. No concerns were noted with the package closecut by the NRC. This event report is considered closed.

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I LER 87-12 The licensee's immediate corrective actions on this event were inspected by the senior resident inspector in November 198 Subsequent corrective actions were inspected during this inspection to verify corrpletion. Corrective actions were verified to be complete, including the following:

t (1) updating of Plant Heatup Procedure 1 POP 03-ZG-0001 (Revision 6)

to include a step to open the LH5I and HHSI cold leg injection valves; (2) addition of a safety function checklist (Modes 1-4) to Plant Operations Shift Turnover Procedure OPGP03-ZA-0063 (Revision 6);

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(3) updating of RHk System Operation Procedure IP0P02-RH-0001 (Revision 7) to verify correct valve, switch and breaker lineu The event described by LER 87-12 was discussed in an enforcement conference on December 30, 1987, and is being considered for escalated enforcement action (EA-240). This event repcrt remains ope LER 87-14 ihe corrective actions of LER 87-14 were verified to be only partially complete. Corrective Action Item No. 1, placement of "

warning signs, was performed by the licensee and verified by the NR LER 87-14 is ope LER 87-15 s The corrective actions of LER 87-15 were verified complet The MEAB log sheets (Procedure 1 PSP 03-ZQ-0002-2, Revision 4) have been updated to ensure heaters of safety-related chillers are o The LER is considered open by the NRC, because the LER/SPR package remains open 6 by the license .

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8 LER 87-20 Requests for information on the modifications suggested in LER 87-20 on the Toxic Gas Monitoring system could not be obtained. The licensee stated that.the modification was rejected by the NSRB, requiring further investigation and revie The LER is ope LER 87-24 Some of the corrective actions of LER 87-24 were verified complete in the fiel Panel ZCP-023 was inspected (in conjunction with corrective action review of LER 87-04) for panel modifications. The LER is ope During the onsite followup of. LERs, several problem areas were noted:

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Using LER 87-06 as an example, root causes of events need to be clearly identified to prevent a recurrence of the even If only the cause is identified, and not the root cause, then the event could be repeate Ensure generic implications to other components and procedures have to be adequately considered. For example, if a component fails, find out what specific item of the component faile Will this item probably fail in other similar applications? If so, replace all similar item An independent technical review of LERs should be performed to help assure root causes and associated corrective actions are properly identifie Timeliness in closeout of LERs by the licensee needs improvement. For example, LEP. 87-06 was ready for closeout in September 1987, but was officially closed out in January 198 '

Licensee closecut of an LER is required prior to closecut of the event by the NR . General Comments Based on the review of the reports, the overall quality of the LERs appeared to be adequate regarding report content and clarity. However, specific items were noted where the LER could use improvement, including: commitment dates for implementation of stated corrected actions need to be delineate several reports were submitted outside the 30-day period allowed by 10 CFR 50.73; the TS referenced in LER 87-12 (3.6.3.1 rather than 3.5.3.1.c) did not appear to be correct;

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9 ensuring acceptable performance levels regarding the establishment, maintaining, and implementation of procedures by operations and nonoperations personnel (paragraph 2.a.); the establishment of controls to ensure conservative interpretations of .the Technical Specifications and to ensure changes to the license

- are reflected, as appropriate, in programs and procedures (paragraph 2.b.); ensure the'needed detailed design _ review of the Toxic Gas Monitoring System addresses the system design requirements, including the equipmen.L wear and single failures (paragraph 2.c.); the improvement in the timeliness in closeout of written reports (paragraph 3.k); root causes of events need to be clearly identified to prevent recurrence of the event (paragraph 3.k);

i generic implications to other components and procedures have to be

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adequately considered (paragraph 3.k); and an independent technical review of LERs should be performed to help assure root causes and associated corrective actions are properly identified (paragraph 3 k.). Exit Interview An exit interview was conducted on January 29, 1988, with attendees noted

in paragraph 1. The scope and results of the inspection were presented to

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the licensee. The LER status was discussed: number of LERs reviewed, LER/SPR packages inspected, LERs considered closed, and which LERs were field inspected. Also, most of the general comments listed in paragraph 4 were presented to the licensee as recommendations by the NRC for LER process improvement The licensee did not identify as proprietary any of the materials provided

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to or reviewed by the inspectors during the inspection.

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