IR 05000498/1988035

Insp Repts 50-498/88-35 & 50-499/88-35 on 880516-0624.No Violations or Deviations Noted.Major Areas Inspected: Preoperational Testing QA Program,Including Control of Records,Audits,Design Control & Maint of Equipment

ML20207B661
Person / Time
Site:	South Texas
Issue date:	07/14/1988
From:	Barnes I, Ellershaw L, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207B657	List: IR 05000498/1988035 ML20207B652
References
50-498-88-35, 50-499-88-35, NUDOCS 8808030091
Download: ML20207B661 (16)

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j APPENDIX  ;

l U.S. NUCLEAR REGULATORY COMMISSION [

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REGION IV a i

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NRC Inspection Report: 50 498/88-35 Operating License: NPF-76 l; 50-499/68-35 Construction Permit: CPPR-129 i

Dockets: 50-498 '

50 499 l

j Licensee: Houston Li hting and Power Company (HLt.P)  !

P.O. Box 1 011 t j Houston, Texas 77001  !

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i Facility Name: South Texas Project (STP), Units 1 and ? i k

1 Inspection At: STP, Matagorda Cour.ty. Texas l Inspection Conducted: Pay 16 though June 24, 1988 q

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) Inspectors: J6n ,~. 4 7 -es - # !

, f L. E. Ellershaw, Feactor Inspector, Materials Fa,te i and Quality Programs Section, Division of l Reactor Safety l

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/ * R. G. Taylor, Reactor Inspector Materials and 7 - o u. - yf

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j Pete j i Quality Programs Section, Division of Reactor j j Safety

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l Accorpanying

Personeel

E. P. Hildebrand Reactor Inspector, Plant Systems  !

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Section, Division of Peactor Safety j i .

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4 Approved: fm 6n.~-. -

7 - e u - rf I 5arnes Chief. Paterials and Quality Date

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Programs Section. Division of Reactor Safety

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es0803oo91 sso7 o l PDR Apocg o woo 499 1 0 PDC r-i

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j Inspection Sumary j

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hc InspectionConductedMayJ,6,,th,roughJune2hj,988,jRep, e ort 50-498/88-35)

Areas Inspected: No inspection of Unit 1 was a:onducted, i 1 l l Inspection Conduc,ted Fay 16 through June 24,1988 (Report 50-499/P8 35), i t

! Areas inspected: Routine, unannounced inspection of the preoperational testing i i quality assurance program including the areas of document control, control of !

i records, audits, design control, and maintenance of equipment. Preoperational '

test activities related to the emergency-standby power system were also examined

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including review of procedures, witnessing of tests, and review of test record l l

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i Results: Within the two areas inspected, no violations or deviations were '

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I DETAILS  !

t Persons Contacted  !

i Principal Licensee Employees

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+#*J. T. Westerineter, Project General Ma.:ager l

• J. I 41 er, 9 General Manager, Nuclear Assurance t

• Wi, ' burg, Plant Superintendent, Unit 1  !

+*D. C. A g, Construction Manager ,

• J. N. Bailey, Engineering & Licensing Manager, Unit 2 l

• J. R. Broadwater Startup Manager  ;

• J. D. Green, Manager, Inte ction & Surveillances I

+#*T. J. Jordar., Project Quality Assurance (QA) Manager. Unit 2

• S. M. Head, Supervising Licensing Engineer i

+ t F. Polishi.k. Project Compliance Engineer  !

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• e M. Burcin, Purchasing Manager

+#J. A. Slabinski, Operations QA Supervisor, Unit 2 JG. L. Pa.'ey, Plant Superintendent, Unit 2 M. C. Sargent, General Supervisor, Document Control

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B. A. Fletcher, Supervisor, Field Cocument Control Center B. K. Meador, Administrative Supervisor, Startup R. L. Balcort, Manager, Audits and Assesstr+nts R. J. Rehkugler, Audit Supervisor 8*S. D. Phillips, Project Compliance Engineer

+M. E. Powell, Supervising Project Engineer

+M. Duke, Staff Engineer Electrical I

i Principal Contr,a,c,toL,mplog E

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+#*E. P. Rosol Site Manager, Ebasco Services, In i

• R. A. Moore, Assistant Quality Control (QC) Site Supe * visor I Ebasco Services, In .!

1. • R. W. Miller, Project QA Manager, Bechtel l

+#*R. H. Medina, QA Supervisor, Bechtel j PC. F. O'Neti, Unit 2 Engineering Manager, Bechtel .

1. R. D. Bryan, Construction Manager, Bechtel l

, +#R. E. Abel, Quality Manager Ebasco Services, In , j NRC Regioy IV Po tonnel

• J. L. Milhoan, Director, Division of Reactor Safety -

• L. D. Gilbert, Reactor Inspector

• E. P. Hildebrand, Reactor Inspector

1. • D. L. Garrison, Resident Inspector

• J. E. Bess, Resident Inspector

• R. B. Vickrey, Rektor Inspector

• G. A. Pick, Reactnr Inspector

+D. M. Hunnicutt, Senior Reactor Inspector i

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The NRC inspectors also interviewed other licensee employees during the course of the inspectio * Denotes those persons that attended the exit interview on May 20, 198 # Denotes those person that attended the exit interview on June 10, 198 + Denotes those persons that attended the exit interview on June 24, 198 . Cuality Assurance Program for Freoperational Testing Document Control (25742)

The purpose of this phase of the inspection was to dete mine if the licensee's program for control of documents such as dra..ir.gs and test procedures as it anplies to preoperational testing activities had Section 17.2.6 of the Final Safety beeneffectively(implemente Analysis Rep 9rt FSAR) and especially paragraph 17.2.6.2 relative to the control of issuance and revision of documents was reviewed. The commitments contained in the FSAR have Leen reiterated in Operations Quality Assurance Plan, Section 8.0, Revision 1 "Control and Issuance of Documents," which also assigns management responsibility

/or the direct implementation and for auditing the implementatio Document users are assigned personal responsibility to cssure that any document.used for safety-related activities is of the latest issu Within the startup organization, which performs the preoperational testing, the startup manager has issued Startup Administrative Instruction (SAI) 6 Revision 9, "Document Control." This procedure provides specific instructions to startup personnel on where they are to obtain the latest versions of docurcents they use in the performance of the testing and directly related activities. It also provides instructions to the personnel on their responsibilities to assure curreatness of any design document used in conjunction with, or referenced by, the test documen Each test procedure contains a listing of applicable design documents such as piping and instrument diagrams that are applicable to the tes Prior to initiating an official test, the test engineer is to verify that the references are accurate and to obtain copies of the documents from the field document control station located in the startup administrative work area. Update verificat.icn is obtained from the field revision list which is updated daily by the design organization and reflects any newly issued or newly revised document The NRC inspector selected a total of 23 design drawings and 5 vendor issued manuals from 3 test procedures where testing has rat been initiated and from one test procedure where the testing has been completed but has not been officially accepted by the licensee's

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joint test grou Thirty-seven changes were found to be outstanding ugainst the nonvendor documents. All were properly referenced in the -

appropriate test procedure and all agreed with the field revision list except for three outstanding changes not directly referenced in the completed test procedure. Review of the latter test package revealed that these changes had originated with the startup test engineers and were included in the test packages as part of startup work requests or nonconformance reports. At the time the test was started, all referenced documents were correct. The test documentation referenced the startup work requests and nonconformance reports at the appropriate place in the test work sheets which adequately connects the outstanding changes inta the record,

In the area of control of the test procedures themselves, SAI-6 requires that after the approval of a given test procedure by the startup manager, the document is forwarded to the startup test records center (TRC) for retention. When it is determined that a specific test is to be initiated, the assigned startup engineer requests a copy of the procedure from TRC. When issued, the copy is stamped on each page with "Official Test Copy" and the issuance logged into a trackirg system in the TRC. If a page in the official copy becomes mutilated or lost during the course of the test, the TRC can reissue that page, stamped as above, as a replacement. The NRC inspector reviewed the completed, but not accepted, procedure noted abev Each page had been stamped as required as were all referenced documents that form a part of tha official test package. The results of the examination of the TRC tracking log relative to the date of issuaace and the date of return of the completed test package agreed with the dates of performance of the test as indicated by the test data sheets and the test daily event log contained within the packag The approved test procedures that had not been started by l

the date of inspection were found in the TRC files and were not stampe Based on the sample of controlleri documents and on the interviews with personnel actively involved in the document control system, it appears that the licensee has a well organized and effectively implemented program for controlling documents utilized by the startup organizatio No violations or deviations were identified in this area of the inspectio b. Control of Quality Records (35748)

The purpose of this area of the inspection was to determine if the startup organization has properly implemented the comitments contained in paragraph 17.2.17 of the FSAR and promulgated in the licensee's Operation Quality Assurance Plan, Chapter 14.0, "Records Control." The latter document assigns management responsibilities for the control of records but places the responsibility for the content of records on the originating organization. Within the

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.startup department, the final quality record is a completed test procedure for a given component, system, or group of systems. The completed test package contains all referenced drawings and associated startup work requests, nonconformance reports, problem identification and resolution reports and other documents used during or generated by performance of the tes As discussed in the preceding section, the TRC has control of all test records during the period before a test is initiated and again af"' a test has been completed in the field. When all action items

. .... completed, in regard to a particular test, that test pex.ge is forwarded to the licensee's joint test group for review d

dnd approva If approved, the components or system involved are turr.ed over to the licensee's plant operations organization. The then accepted test procedure is forwarded to the licensee's records management sy3 tem group for permanent retention in the records vaul Dise.ussions with other NRC inspectors indicated that they had reviewed a substantial number of fully completed and accepted preoperational tests that had been placed in the permanent records vault and had found them consistently properly stored, legible and complete. Therefore, the NRC inspector examined only the control of records within the TRC. The NRC inspector selected Procedures 2-CC-P-03, 2-0G-P-02, 2-FH-P-01, 2-WL-P-01, 2-SI-P-04, t 2-RH-P-01 and 2-EW-P-02 from a library of preoperational test 1 procedures maintained in the QA area. It was found that records in the TRC indicated that the first four of the above procedures had been drawn from the TRC during the period from February 13 through May 15, 1988, as "Official Test" copies and had not been returned as completed. Procedure 2-SI-P-04, as mentioned earlier, was still in the TRC as field test complete but not accepted by the joint test grou TRC records indicated 2-EW-P-02 and 2-RH-P-01 had been transmitted to the vault with receipt acknowledge The receipt ,

indicated that these were entered in the record management system '

computer as files M5.2.2 and M23 respectivel The licensee's control of quality records generated within the area

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of startup testing is considered to be well controlled by experienced and knowledgeable personne '

No violatinns or deviations were identified in this area of tne inspection, Audits (35],4,11 The purpose of this area of the inspection was to verify that the -

licensee has developed and implemented a quality assurance program relating to audits of activities that is in conformance with regulatory requirements, coninitments, and industry guides or standard .

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The NRC inspector reviewed the following documents to verify that administrative controls exist and that they provide measures to assure that audits are scheduled and performed by qualified personnel. In addition, the review was performed to assure that the mechanisms required for correcting deficiencies identified during the performance of audits were clearly established and that responsibilities for implementing the audit program were delineated in writin Document N Revision Date Title QAP- Plant and Vendor Audits

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QAP- QAP- Deficiency Reporting

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, QAP- QAP- Training, Qualification 1 and Certification of Audit Personne IP-4.4Q 2 10-02-87 Performance of Quality Assurance Audits and Surveillance Activities To assess the implementation of these documents, the NRC inspector reviewed the Nuclear Assurance 1988 Audit Plan, the four audit report packages performed in 1988 applicable to Unit 2, and the qualifications of the personnel who performed the audits. At this time, the audits have been performad as scheduled. The four audits applicable to Unit 2 were identified as: B1-Nuclear Operations (NO), Nuclear Engineering & Construction (NE&C) Information Management (IM)

Organization and Staffing; B2-NO, NE&C, IM Personnel Training and Qualification; C-N0/Nonconformance Control and Corrective Action; and 08-NO, NE&C Test Control, i i

Each audit package contained the audit scope which established the purpose of the audit and identified the applicable and reference ,

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documents, including the appropriate section of the lechnical l

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Specification. The packages also contained the audit report, checklists, supporting documentation, and copies of deficiency reports where deficiencies had been identifie The audits appeared to be comprehensive and complete. It was noted that the auditors had identified a number of "concerns" in addition to deficiencies. The concerns are those things which are not deficiencies, but if allowed i l to continue, could conceivably become deficiencies. With the l l exception of Audit B2, which had just been completed, all concerns ,

and deficiencies had been responded to by the affected organizatio l The responses to the concerns and deficiencies had been reviewed and I accepte The requirements for verification of the completed ;

i corrective actions had also been established and noted for future l 1 audits in those areas. The NRC inspector reviewed the qualifications of the eight auditors involved in the performance of the four audits.

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. 8 The records established that the eight auditors had been trained in accordance with QAP-2.1, which endorses and complies with .

ANSI N45.2.23-1978, and Regulatory Guide 1.146-August 198 The NRC inspector concluded that the licensee had established a comprehensive audit program which has been implemented and performed by qualified personne No violations or deviations were identified in this area of the inspection, d. Design Changes and Modifications (357Q The purpose of this phase of the inspection was to verify that the licensee has implemented a program for the cf.ntrol of design changes -

and modifications that is in compliance with paragraph 17.2.3 of the FSAR. Of particular interest was the application of the controls to those plant systems that had been turned over from construction to the licensee's startup organization for prerequisite and preoperational testin The licensee has promulgated the commitments of FSAR paragraph 17. in his Operations Quality Assurance Plan via Section 6.0, Revision 2

"Design and Modification Control." This document establishes general

, requirements for the control of design changes and modification control and assigns responsibilities for implementation to the vice president for operations and to the vice president of the engineering and construction organization. The startup department is established as a separate component of engineering and construction. Within the startup department, the startu Acministrative Procedure (SAP)p -3,0,manager Revisionhas issued Assurance 5,"Quality Startup Plan," which sets forth the overall requirements for control of quality within the group. SAI-3.0, directs the user to SAI-12

"Problem Identification & Resolution." Revision 5 of sal-1 provides three primary avenues for resolution of problems that are encountered during testing. The first avenue is through the startup field report, which is used when the startup engineer in charge of a particular test, encounters a problem that appears to require design engineering assistance to resolve. sal-12.0 requires that the report be sent to the engineering organization which in turn will process the report under Bechtel Engineering Corporation (BEC),

Engineering Department Procedure (EDP) 4.70, "Startup Field Reports."

Revision 2ST of EDP 4.70P provides several avenues for resolution of the identified problem. When the resolution takes the form of an engineering change, the responsible BEC engineer is required to issue a fielo change request, a specification change notice, or a design change notice as appropriate to the circumstances as de:cribed in other BEC EDP Once issued, these change documents then become the responsibility of startup to determine how implementation is to be achieve .

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The second avenue available to the startup engineer to resolve problems is the direct issuance of a field change request (FCR).

This avenue would generally be used when the startup engineer is confident that he knows the solution to the problem and, therefore, can suggest the solution in writing. The request is forwarded to BEC for approval prior to or concurrent with implementation of the change, the latter occurring only with startup management approval and H so noted on the FCR. The BEC responsible engineer has the right to change or correct the recomended solution. Again, once the FCR is approved, startup is responsible for implementatio TFe third avenue of resolvirg problems invo?.es only BEC controlled electrical cable installation and terminations. BEC has implemented

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t program for electrical field installation and termination referred co as the EE580 program. This program is a conputerized data base that contains data as to the routing of each cable through the raceway system and for the termination of each cable on both end The scheduled termination point of each wire within the cable is ;

indicated on a card which can be printed out and provided to installer, inspector, or test engineer. Wher, a startup engineer believes that a cable is incorrectly terminated as shown on the EE580 card, he initiates a "Startup EE580 Termination Request Form" which documents the existing termination data for a given cable and lists what he believes would be the correct termination under a request colum The parent electrical drawing for the electrical circuit element involved is also referenced. Each form is uniquely serial numbered for traceability in the records system. Upon internal I approval by startup management, the form is forwarded to BEC for !

approval. If approved, the form data is authorization for changing the physical terminations. Cortection to the computer data base follows, generally within a relatively short period of tim The startup organization is also responsible, under SAI-3 and SAI-12, for reporting via nonconformance control pr-ocedures, any condition identified during the course of testing that is not in conforinance to existing design engineering documentation.

, The NRC inspector selected ten. Field Change Requests and five EE580 Termination Requests from three recently completed electrical system preoperational tests to vet ify that the changes had been processed in accordance with the above procedures. At the time of the inspection (June 20-24, 1988), substantially all of the tests eat have been I completed in Unit 2 are electrical system tests. The bulk of the i major piping and instrument systems are tested individually and together under the overall hot functional test program, Each of the above 15 changes had been tracked in the licensee's N ter

, Completion List tracking system from initiation through final closure i and were properly recorded within the affected test procedure. The I below listed change documents were found to have been properly issued i with the approval of both the BEC lead discipline engineer and the project engineer and all were available through eitner the Field l

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• 10 Document Control system for the FCRs or from the Record Management System computer for the EE580 change Field Change Requests Affected Drawing SE-01437 9-E-PK04-02 Rev. 6 SZ-01444 CCP-CJ-EM-0369 Rev. O HSE-01462 5Z-10-9-Z-42122 Rev. 5 XSE-01482 8121-01133-GU Rev. B SE-01542 8121-01095-GV Rev. B  :

E-01704 8121-01077-GU Rev. B SE-01719 8121-0106)-GU Rev. B SE-01753 8121-01063-GU Rev. B SE-01793 OE-PGAA-01 Rev. 4

HSE-01877 9E-PK01-01 Rev. 5 EE580 Request N Affected Cable '

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287-0004 C2MB03CISL-2 C2MB03CISC-2 287-022 A2PLO1J2WB-1 & 2 87-0279 03CISD-2 B2MB03CISH-2 87-249 B2PK02C2WA-1 & 2

. C2PK02C2WA-1 & 2 287-(093 B2PLO5J1WR ,

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B2PLO5J2WR The NRC inspector obtained a printout of the computer data base l regarding the above EE580 requests and found that the current data i entries were in agreement with the approved change request information submitted by the s:artup enginee The NRC inspector also reviewed 26 nonconformance reports that had been issued in relation to the tnree selected tests. The review indicated that no engineering action was required to resolve any of the identified deficiencies. All of the deficiencies involved correction of workmanship items or repair or replacement of damaged

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1) It appears that the startup organization has complied with the i requirements of the Operations Quality Assurance Plan and with the implementing procedures. It also appears that the interface between

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the startup organization and BEC has been functioning in an effective l manne '

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. 11 e. Maintenance (35743)

The objective of this portion of the inspection was to determine whether the licensee has established and implemented a QA program pertaining to maintenance activities that ic in confonnance with regulatory requirements, and industry guides'or standard The NRC inspector reviewed the following licensee documents which describe the maintenance program:

Document Revision Date Tit]

FSAR Chapter 13 61 June, 1987 Plant Procedures FSAR Chapter 17 61 June, 1987 Quality Assurance OQAP Section Maintenance, Installation of Modifications, and Related Activities i SAI-4 3 9-18-87 Equipment Clearance SAI-7 3 9-25-87 Preventive Maintenance i Program i SAI-11 13 2-19-88 Startup Work Requests i OPGP03-ZM-0002 15 6-15-88 Preventivs Maintenance (PM) Program OPGP03-ZO-0007 3 6-8-88 Conduct of Maintenance OPGP03-ZM-0018 1 5-17-88 Sa'ety/ Relieve Valve Program OPGP03-ZM-0003 18 6-15-88 Maintenance Work Request Program OPGP03-ZE-0020 0 1-16-87 Post-Maintenar,ce Testing Program OPGP03-ZM-0006 2 5-23-88 Control of System Cleanness Ouring Maintenance j OPGP03-ZM-0012 2 9-25-87 Housekeeping ,

OPGP03-ZO-0001 7 3-17-88 Equipment Clearance i OPGP03-Z0-0004 8 6-3-88 Plant Conduct of

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Operations OPGP03-ZO-0027 4 10-28-87 Locked Yalve Program OPMP04-RM-0005 1 12-30 e6 Reactor Makeup Water

.l Purrp Maintenance OPMP04-ZG-0010 1 6-3-86 Limitorque Operator Maintenance, Model SMC-4 OPMP05-ZE-0300 3 3-21-88 Limitorque MOV Motor inspection and Lube OPMPC5-ZE-0306 0 9-9-87 Limitorque Operator Maintenance, Models SMB-0 through SMB-4 SMB-4T, and SB-0 through SB-4 l

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IP-3.150 0 9-19-86 Control of Special .

Processes Manual 3 --

Post-Maintenance Test.ing Refarence Manual Test Plan 0 -- Pump and Valve Inservice Test Plan These documents were established to implement and control the maintenance program. While some are necessarily of a generic nature, most are specific and address the mandatory elemante M the orogram; i.e., corrective naintenance, equipment control, motor operated valve maintenance, preventative maintenance, special processes, cleanliness controls, and housekeeping controls. The documents are comprehensive and clearly define the requirements which address criteria, methods,

responsibilities, and records. A similar inspection was performed and documented in NRC Inspection Report 50-498/87-26 (Unit 1) in

.hich an open item (8726-09) consisting of several observations made by the NRC inspector, indicated potential program weaknesses. The licensee addressed thrse s observations by strengthening the existing procedures and providing additional training to the affected personnel. The open item was subsequently closed in NRC Inspection ,

Report 50-498/87-3 .During the current inspection of the maintenance program for Unit 2, the NRC inspector verified that the previously identified observations relative to the Unit 1 maintenance program had not been allowed to inadvertently resurface, with respect to the Unit 2 program. In addition, subsequent to the training provided to Unit 1 maintenance personnel, similar training was provided to those personnel assigned to Unit 2.

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It would appear that the licensee's maintenance program is comprehensive and, if followed, should provide the necessary controls to meet all regulatory requirements and licensee commitment To assess the implementation of the pisgram, the NRC inspector: (1)

reviewed the maintenance work request (MWR) printout and selected three completed corrective maintenance activities in order to review <

the applicable documentation and to visually verify that the work had '

been accomplished (2) observed a corrective maintenance activity in progress, and (3) reviewed the preventive maintenance (PM) schedule and selected five active PMs in order to verify that the PMs were performed in accordance with the schedule and specified procedure It should be noted that the PM program is extensive and will include .,

in excess of 9000 scheduled PM activities. There are approximately ,

2600 PMs which have been approved for implementation to dat i MWR No. MS-87009437 was initiated on May 12, 1987, in order to resurface both sides of a badly pitted shim plate to be used with the ;

upper lateral support of Steam Generator 201 The MUR was properly I

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, filled out and signed by the responsible persons. The necessary work .

instructions were specified as was a QC inspection point. The craftsman recorded e summary of his work and included the type and identity of the measuring and test equipment used. The QC inspection operation was signed and dated, and the inspection report number was recorded. This particular corrective maintenance could not be visually verifled by the NRC inspector because the shiin plate had

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been installe MWR No. DX-87010736 was initiated on May 26, 1987, in order to drill a 1 9/16-inch diameter hole in each of four plates used in the installation of large bore hangers in the A and C bays of the diesel generator building. The MWR was properly filled out and signed by responsible personnel. The necessary work instructions were stated on the MWR continuation sheets which referenced the applicable

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drawings. The craftsman recorded a summary of his work activity and all appropriate sign-offs were entered. The NRC inspector verified

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by visual inspection that the stated wcrk had been accomplishe MWR No,'FW-49217 was initiated on March 16, 1988, in order to fabricate a limit switch mounting bracket for feedwater isolat.un valve A2FWFV714 The MWR was properly filled out and signed by the responsible personnel. The necessary work instructions were stated on the MWR continuation sheets which also included the reference drawing, procedures, and a field change request. The craftsman recorded a summary of his work, and the description, identity, and calibration due dates of the measuring equipment used. All operations were signed off. The NRC inspector verified by visual inspection that the stated work had been complete The NRC inspector witnessed the disassembly, repair, reassembly, and post maintenance testing performed on the residual heat removal pump No. 2C outlet pressure relief valv This activity was accomplished under MWR No. CC-68856, which had been initiated on June 6, 1988, as a result of a leaking valve body. All operations specified on the

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MWR were complied wit The repairs included cleaning and replacing two gasket guides, lhe guides were issued from stores on Material Issue Slip k. . 910069 dated June 23, 198 The Level !! mechanic recorded the description, identity, and calibration due date of the pressure gauge used for testing. A QA representative witnessed the test and signed off the operation on the MWR, The hRC inspector reviewed the following five PMs: Electrical Maintenance (EM) -2-AF-87016195 for lubrication and inspecting motor driven auxiliary feedwater pump No. 12: EM-2-SI-87002134 for rotating the shaft of the 400 horsepower safety injection pump motor; '

Instrumentation and Control (IC) -2-B5-87016477 for inspection / cleaning of reactor protection set II; Mechnical Maintenance (MM) -2-CC87016680 for inspection / lubrication of ;

. component cooling water pump 2A; and MM-2-DG-87000580 for inspection

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of standby diesel generator No. 21. In each case, the maintenance

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had been performed as scheduled. All of the applicable documentation had been properly completed and signed by the cognizant personne No violations or deviations were identifie It would appear that the licensee had adequately implemented the maintenance program for Unit !

3.- Unit 2 Preoperational Test Program Activities Emergency-Standby Power Supply System Procedure Review (70341).

During this inspection period (May 16-20,1988), preoperational testing of standby diesel generator (SDG) number 22 (Train B) was ia progress. Review of controlling Procedure 2DG-P-02, Revision 2,

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revealed the following:

o The procedure was well written and incorporated coments and changes which occurred during performance of Unit 1, SDG testin o The procedure included test acceptance criteria that was consistent with the applicable requirements of the South Texas Project FSAR, Chapter 14 -

o Appropriate prerequisites and precautions were included, l'

o Engine operating logs were attached as part of the procedure and were required to be used during the engine endurance test performance, Emergency-Standby Power Supply System Test Witnessing (70441).

NRC inspector coments related to this area are provided below:

o The test engineer conducted a pretest briefing for all involved personnel in the Unit 2 control room prior to initiating the tes The test engineer ensured that all personnel involved were knowledgeable of their individual responsibilitie l Applicable precautions and prerequisites were addresse o Verification of prerequisites by the test engineer prior to

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performance of the test was noted by the NRC inspector to be

, considerably more informal than expected. During the 3' verification process it was observed that the engineer would ask the unit supervisor the status of a system's availability to support the tes The replies were sometimes inconclusive in that they contained statements such as "as far as I know," or

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"the last time I checked," and "I think so." The test engineer was observed to sign off several of the prerequisite items, apparently based on the unit supervisor's replies. One of the verification steps performed in this manner was relative to the

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availability of the SDG 22 fire protection' system. When questioned by the NRC inspector regarding his verification of the prerequisites, the test engineer stated that he had previously verified most of the prerequisite steps and that he would reverify them again prior to actually initiating the tes Subsequent discussiors with the shift supervisor regarding the method of verifying SOG 22 fire protection system availability indicated that there was no indication of status provided in the control room.

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In order to varify system status, it would be necessary to perform a valve lineup verificatio Verification of prerequisites by the test engineer prior to performance of a preoperational test is required by paragraph 14.2.4.2 of the FSAR. The observed lack of formality was brought to the attention of the startup nianager and subsequently discussed with senior licensee management during the exit intervie o Testing was observed to be conducted in a fonnal and professional manner, the test procedure was followed step by step. The test engineer was knowledgeable of the test procedure and the 50G and associated systems. Comunications were noted as being very good between the test engineer and other assigned personnel. A reactor plant operator was available to operate the systems and equipment at the direction of the test engineer. It was also noted that an operations quality control inspector / engineer was closely following the performance of the tes o In sumary, the testing evolution observed was well controlled by the test engineu except for the relative informality of the prerequisite verification steps, t preoperational Test Results Evaluation (70400)

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In addition to monitoring testing in progress, a review was performed :

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of two test procedure packages which had been completed and accepted by the licensee's joint test group. These procedures were stored as ;

completed test packages in the licensee's permanent plant records vault. The procedures reviewed were:

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2RS-P 03. Reactor Trip Switchgear Preoperational Tes CH-A-02. Technical Support Center HVAC Chilled Vater System Acceptance Tes These procedures were reviewed for completeness and adequacy of post-test review and for compliance with the applicable FSAR

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Chapter 14 acceptance criteria. The packages were well assembled and were legible. Changes and corrections to the procedure were made in accordance with approved administrative procedures. It appeared that the review process had been thorough as evidenced by the comments included by the reviewer '

No violations or deviations were identified in the area of preoperational test activitie . Exit Interview i

The NRC inspectors met with the licensee as denoted in paragraph 1 to summarize the scope and results of the inspection.

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