IR 05000498/1988052
| ML20204G393 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/12/1988 |
| From: | Robert Evans, Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20204G384 | List: |
| References | |
| 50-498-88-52, 50-499-88-52, NUDOCS 8810240106 | |
| Download: ML20204G393 (17) | |
Text
.
,
.
.
,
.
'
APPENDIX U.S. NUCLEAR REGULATORY COMMIS$!ON
REGION IV
NRC Inspection Report:
50-498/88-52 Construction Permit: CPPR-129 50-499/88-52
-
,
Dockets:
50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)
P.O. Box 1700 l
Houston, Texas 77001 Facility Name:
South Texas Project. Units 1 and 2 (STP)
l l
Inspection At:
STP Site Matagorda County, Texas inspection Conducted:
August 8 through September 2, 1988 i
Inspectors:
exd / M
'(
lb Ob Dorwin R. Hunter, Senior Reactor Inspector Date Ope tional Programs Section, Division of P a tor Safety
'B N
'
Jo p 79
\\ ottert EVahs, Reactor Inspector, Operational Date
'
.
FYogra # Section, Division of Reaction Safety
'
f
th la of A Approved:
.
>K
J; (E. Gagl ardo, Chief, Operational Programs Date
Shetion. Division of Reactor Safety
1
Inspection Sumiry l
Inspection Conducted Aucust 8 through Septerber 2, 1988 (Report 50-498/88 52; l
50-4 /88-52)
Areas inspected: Routine unannounced inspection of the maintenance procedures, j
emergency procedures, and Technical Specifications associated with STP-2.
8810240106 891017 FDR ADOCK 0500
.
- -
.
9
.
.
,
l
.
.
.
Results: Within the three areas inspected, no violations or deviations were identified. Two unresolved items were identified (paragraphs 3.2.2. 3.3.1, and i
5.5) and will.be subject to future in-depth inspections.
,
t l
t
i l
,
r I
t
?
I L
)
{
i I
!
l f
!
t
,
!
i l
I
--._
. _ __
-
.-.
.
.
_ _, _.
_ _ _ _.. - _,
_.. _ _.
_ _ _. _ _. _..
_ _. _ _ _. - -
_ - _ - - _. _. _. _.
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
.
.
.
!
-
.
-
.
-3-l
<
DETAILS 1.
Personnel Contacted i
HLAP
- G. L. Parkey, Plant Superintendent Unit 2 (
- J. D. Green, Manager, inspection and Surveillance
,
J
- J. A. Slabinski Operations QC Supervisor, Unit 2
!
'
- V. R. Albert, Manager, Nuclear Plant Engineering
- S. E. Hill, Maintenance Supervisor, Unit 2
- S. O. Phillips, Project Con 911ance Engineer
- M. F. Polishak, Lead Engineer
- M. L. Duke Staff Engineer i
P. R. Bufkin Lead Electrical QC Inspector J. S. Gilstrap, Lead Mechanical QC Inspector
B. J. Mower Mechanical Maintenance Supervisor l
H. R. McNeal Electrical Maintenance Technical Supervisor i
J. Lewis. I&C Supervisor i
- J. T. Westerreter, General Manager l
- S. M. Dew Operations Stpport Manager
!
'
'
- M. A. McBurnett Operations Support Licensing Manager
- D. N. Brown, Construction Manager
- W. G. Wellborn, Supervising Project Engineer l
- T. J. Jorden Project QA Manager l
- S. M. Head Supervising Project Engineer j
j
- A. W. Harrison, Supervising Project Engineer
- J. Bailey, Engineering and Licensing Manager
!
- J. E. Geiger, Nuclear Assurance General Manager i
- S. L. Rosen, Operations Support General Manager j
T. Mitchell, Plant Operations Support Supervisor t
'C. R. Beauers Radiation Section Supervisor
- J. R. Lovell Technical Services Manager i
i
- D R. Keating, Quality Engineering Man g er
- M. Wisenburg, Plant.iuperintendent Unit 1 j
- W. S. Blair, Maintenance Manager
- L. Giles. Operations Manager, Unit 2
,
l
- J. l.oesch, Plant Operations Manager i
- S. Eldridge, Plant Operations Support Manager
'G. Ondriska Startup Supervisor i
Bechtel Engineer Corporation (BEC)
l
<
)
- C F. O'Neil. Unit 2 Engineering Manager
- R. D. Bryan, Construction Manager
,
'
- L. W. Hurst, Project Manager q
- R. W. Miller, Project QA Manager l
I
l I
'
~
l
'
.
.
.
_ _ _ _ _ _ _ -
-_
_--
______ _- _ _ _
.
.
.
'
!
.
,
-4-
Ebasco Service. Inc.
,
- E. P. Rosol. Site Manager
- R. A. Moore. Assistant qC Site Supervisor
- R. Abel, Quality Program Site Manager
!
- W. M. Purdee, QA Site Supervisor p
Other personnel of HL&P, Bechtel Engineering Corporatien, and Ebasco
!
Service, Inc., were contacted and attended the exit interviews.
[
2.
Docurents Reviewed
Letter, HL&P to NRC, dated June 1, 1988, Unit 1 and Unit 2 Corbined Technical Specification Submittal
Lesson Plan, dated June 22, 1988 Differences Between Unit 1 and
.
Unit 2
!
Letter ST-HL-AE-2770, HL&P to NRC dated August 22, 1988, Response to i
NRC Ccncerns Regarding Emergency Operating Procedures
I Letter ST-PL-AE-2080. HL&P to NRC, dated April 15, 1987, Response to l
'
NRC Questions on Procedures Generation Package i
Letter St.HL-AE-1848, HL&P to NRC, dated Febraury 11, 1987, Response
'
to NRC Coments on the Procedures Generation Package
,
Letter ST-HL-AE-1266, HL&P to NRC, dated June 14, 1985. Procedures
Generation Package
3.
Maintenance Procedures Selected raintenance program administrative procedur<s and implementing t
procedures were reviewed to ensure that controls had been established,
which addressed the requirements.
!
l 3.1. Background and Requirerents
!
Discussions and re-ord reviews revealed that the Unit 2 mintenance activities were being controlled almost identically to those in Unit 1, and the necessary Unit 2 plant-specific procedures were being reviewed and approved in accordance with established administrative controls. Managerent had established a completion date for all the required procr.dures (about 1100) for September 30, $988. At the time of the inspection the licensee had completed about 40-50 percent of the required procedures and was reevaluating the scheduled completion date.
The raintenance program and maintenance procedures were reviewed for fomat and content to ensure the safety-related activities were controlled aro' the quality of the equipeent maintained. The raintenance program and raintenance procedures were reviewed considering the following requirements and guidann:
. _ - _ _ _ _ _ _ _ _ _ _ _ _ _
.
,
.
,.
-
,
-5-
\\
i Sections 13.1 and 13.5; STP FSAR, Section 17.2., STP Operational QA
,
Program; Appendix B to 10 CFR 50; STP Technical Specifications.
Sections 6.5.3 and 6.8; Appendix A to Regulatory GJide 1.33-1978; ANSI N18.7-1976; ANSI N45.2-1977; end ASME, Section !!!, NA 4000.
3.2 General Procedures i
The inspector reviewed selected plant administrative procedures
'
associated with the STP maintenance program including the following:
OPGP03, ZA-0002, Revision 13 Plant Procedures OPGP03, ZA 0007, Revision 4, Classification of Procedures
OPGP03, ZA-0010 Revision 11 Plar.t Procedure Compliance, i
Implementation, and Review t
I
OPGP03, ZA-0039. Revision 8. Plant Procedures Writer's Gufde (FCR 88-1270)
[
OPGP03, 28 0009, Revision 1 t.ubrication Monitoring Program i
OPGP03, ZE-0004, Revistor 7. Plant Surveillance Programs
I OPGP03, ZE-0005, Revisten 9. Plant Surveillance Frocedure
l
Preparation
!
!
!
OPGP03, ZE-0020 Revision 0. Post-Maintenance Testing Program l
,
r i
OPGP03, ZH-0001, Revision 12. Measuring and Test Equiprent
,
Control Program
l OPGP03, ZM-0002, Revision 15 Preventive Maintenance Program
OPGP03, TM-0004, Revision 4. Lubrication Progran
!
OPGP03, ZM-0003. Revision 18. Maintenance k'ork Request Program
i OPGP03, IM 0016. Revision 0, Installed Platit Instrumentation
Calibration Verification Program i
OPGP03, ZM-0021. Fevision 0, Control of Configurat %. W;es
!
During Kaintenance or Troubleshooting
,
!
OPGP03, Z0-0001, Revision 7. Equiprent Clearance
e i
OPMP01, ZA-0004., Revision 5. Maintenance Procedures l
,
!
l QCP2.0, Revision 3. Inspection Activities l
"
,
t
- -
-
.
.
.
o -
,.
,
-6-The procedures appeared to be well-written and inclusive of the requirements with only a few corraents and concern., which were reviewed with licensee representatives.
3.2.1 Section 2.0, Definitions, of OPGP03-ZM-0003, Maintenance Work Request Program; Section 2.0, Definitions, of OPGP03-ZA-0007 Classification of Procedures; and Section 5.4, Determination of Required PMT, of OPGP03-ZE-0200, Post-Maintenance. Testing, contained requirements regarding the maintainance of equipment including "repair" activities. The definition of. "repair" was the "process of restoring an item to a condition such that the capability of the item tn function reliably and safely is not impaired even though the item does not meet the original required condition." This usage of "repair' was discussed with the i
licensee representative to ensure that the 5 ' air' dctivities could not result in "modification" activities,'a change to the drawings or specifications, and require har.dling within the
'
design control program (de31gn, design review, design verification, and safety evaluation considerations).
Geneally, the maintenance activities discussed in detail in the standards and guides,
,
address the activities as "rework" or "like-for-like" replacements
'
rather than "repair" or "use-as-is" activities. The licensee representative indicated that the use of "repair" was for
!
performing activities within the specifications such as "lapping"
,
or "cutting" valve seats and "repair" of ASME Code class components.
!
However, the licensee representative noted that the use of the
!
term "repair" would be reviewed to ensure that no "modifications"
!
to equipment could occur as "repairs." The NRC inspectors had i
,
'
no further questions regarding this matter at this time.
3.2.2 Procedures OPGP03-ZA-0002, Plant Procedures; OPGP03-ZA-0039,
!
Plant Procedures Writer's Guide; OPGP03-ZM-0003, Maintenance Work Request Program; and OPMP01-ZA-0004, Maintenance Procedures, did not contain requirements or guidance to ensure the establishment
of quality inspect 1un points within the procedures regarding
,
critical characteristics to assure the quality of the activities
(workoperations).
Document review and discussions with personnel revealed that the i
licensee practices, in most cases, consisted of the consideration
'
of quality inspection points by the quality control group during the preparation of a work package, imediately prior to the work
operation.
Furthermore, Procedure QP2.0, "Inspection Activities,"
'
Step 6.7.3, provided guidance for QC to concentrate on major maintenance activitics rather than all safety-related maintenance activities, which included routine, nonroutine, preventive, calibration, testing, etc.
Personnel interviews and document reviews confirmed this philosophy and practice. The procedure reviewed for perfoming the more routine, repetitive type maintenance activities (paragraph 3.3) such as preventive
_
-
.
-
.
,.
,
-7-maintenance, equipment removal and overhaul, and calibratien did not contain specifically identified inspections of the apparent critical characteristics of the work operation. The critical characteristics would include, but not be limited to, such items as cleararces, locking device installation,' tack welds installation, application of heat to components, certain parts installation, and cleanliness, in order to ensure cc.itinued equipment operation during accident conditions. This issue has the potential of being a violation of Criterion X of Appendix B to 10 CFR 50, and will be considered an unresolved item (498/8852-01; 499/8852-01)
pending additional inspection of maintenance activities.
Notwithstanding, the lack of specifically ider.tified quality inspection points in the procedures, the procedures reviewed generally contained adequate detail and, acceptance criteria, and the required documentation regarding the work operation performance was provided by the craftsperson/ technician.
The review by the NRC inspectors revealed that Procedure OPGP03-ZA-0010. "Plant Procedure Compliance, Implementation, and Review," addressed independent verification, in detail, providing the definition, application, responsibilities, methods, and documentation of the activity (value position, date, and initials).
Procedure reviews and interviews revealed tht this quality inspection ("peer" inspection) activity appeared to be adequately specified and controlled.
For instance, the procedure provided detailed guidance for the required use of the independent verification (inspection) if the item would render the component /
systems incapable of performing the designated safety function.
The independent verification function provided for the inspection /
verification of a predetermined item which would render the component / systems inoperable of performing the designated function, as approprSte. This specific aspect of independent inspection appeared to be adequately controlled and specified.
No other violations or deviations were identified in the review of this program area.
3.3 Maintenance Implementing Procedures
The inspector reviewed selected maintenance implementing procedures associated with the STP equipment including the following:
OPHP01-ZA-0032, Revision 6 Vendor Calibration of Measuring and Test Equipment i
0PMP04-AF-0001 Revision 5, Auxiliary Feedwater Power Maintenance (FCR 88-1086) FCR 88-1196)
OPMP04-CC-0001, Revision 6, Component Coding Water Pump Maintenance
'
.
.
' '
..
,
-8-
OPMPO4-DG-0007, Revision 1. Standby Diesel'Generat'or GT-24 Turbo Charger Maintenance OPMP04-MS-0009, Revision 0, Main Steam' Safety Valve Maintenance OPMP04-RC-0008, Revision 3, Pressurizer Safety Valve Removal and Reinstallation OPMP04-SI-0002, Revision 2, tijgh Head Safety' Injection Pump Maintenance OPMP05-NA-0002, Revision 2, 4160V Gould Tests (FC88-1038)
OPMP05-NA-0005, Revision 0, General Electric 4160 Volt Breaker Tests (NSR)(FC88-1362)
IPHP05-NA-1016. Revision O. Switchgear Maintenance - 4160 Volt Bus ID Cubicle 16 1PMPOS-NA-1017, Revision O. Switchgear Maintenance - 460 Volt Bus ID Cubicle 17 OPMP06-ZT-0115. Revision 2. Calibration of the Newpost 264 Series Digital Pyrometer IPMP07-LM-0100, Revision 2. Reservoir Makeu Valve Monthly Preventive Maintenance (NSR) p Pumps and Discharge OPMP07-ZI-0001, Revision 0, I&C Valve Lineup RCB (FCR 88-0341)
2 PSP 02-RC-0439, Revision 0, RCS Flow Loop 3 Set 3 ACOT (F-0439)
2 PSP 05-RC-0439, Revision 0, RCS Flow Loop 3 Set 3 Calibration (F-0439)
The procedures appeared to be generally acceptable, with some exceptions.
The procedures included the proper detail to be performed by a qualified cra f tperson.
The comments and concerns associated with the exceptions were discussed with the licensee.
In the majority of instances the concerns were considered to have minor safety significance; however, in the following instances the concerns appeared to have more safety significance:
3.3.1 The maintenance arocedures regarding the auxiliary feedwater i
pumps, the high lead safety injection pumps, the component l
cooling water pumps, and the Standby Emergency Diesel Generator l
GT-24 turbocharger included general steps specifying removal and reinstallation of piping, electrical and instrumentation components, and insulation as necessary to perform the maintenance on the equipment.
The procedures did not include or reference the procedures associated with the steps required to perform these activities, which may include such operations as rigging, i
torquing, cleanliness, handling, and storage.
Consequently, I
.
.
'
.
,,
,
.g.
specific performance steps and the inspection requirements associated with such activities were not fully addressed in the procedures. Document reviews and personnel interviews indicated that during the work review process specific procedures were written and considered the needed steps and acceptance criteria regarding the activities.
Further, inspections of the safety-related activities would be considered at the time by the QC personnel were assigned to the work planning activity.
This was an area noted by the inspector where tne procedures should be
-
written early in plant life and should be more specific to ensure the safety-related work operation was adequately controlled and inspected.
3.3.2 The maintenance and calibration procedures reviewed did not include adequate quality inspection The licensee utilized QC inspection points (QIPs) points.
, QC notification points-(QNPs),andQCverificationpoints(QVPs).
These QC points specified in the safety-related maintenance and calibration procedures were limited in number and scope.
The few instances where QC inspections were provide! within the procedures only addressed cleanliness and condition of parts and torqJing of fasteners. Other potential critical characteristics, which were not required to be inspected by the procedures, included measurements, component heating, as found/as left data, 0-ring replacement, lubrication, seal installation, special processes, visual checks, locking device l
installation, drain plug installation, and cleanliness.
Interviews revealed that maintenance pre-planning activities may include these items in the instructions provided by the work planners; however, all potential critical characteristics associated with the safety-related work operation may not be detennined and noted in the instructions.
The NRC inspector reviewed 14 safety-related maintenance and calibration procedures and none of the procedures contained consistent and necessary qualification control inspection points to assure continued equipment operation during accident conditions.
This matter was discussed with the licensee and the programatic aspects of this concern are included in paragraph 3.2.2 as an apparent violation.
,
No other violations or deviations were identified in the review of this
program area..
4.
Technical Specification Review The NRC inspectors reviewed the Unit 1 and Unit 2 Combined Technical
'
Specification Submittal, dated June 1, 1988, from HL&P to the NRC, which annotated the required changes to the Technical Spectifications (TS).
5 elected requested changes were reviewed to ensure that the specifications ure clear. The changes included both editorial and substantive changes and are presently being reviewed by the NRC.
I
'
-
- -
.
.
.
,
-
.
.
.
.c
-
,.
,
-10-4.1 Reactor Coolant System Pressure / Temperature Limits The change provided specific heatup and cooldown curves for STP Unit I and Unit 2.
'
4.2 D. C.- Sources
The change provided specific identifiers for STP Unit 1 and Unit 2 for Battery Banks A, D, B, and C.
'
4.3 Radiation Monitoring - ESFAS The change provided for inclusion of the E8FAS radiation monitoring
'
instrumentation in the ESFAS bases of the TS in accordance with the
,
STP design.
'
4.4 Reactor Vessel Toughness
,
The change provided the STP Unit 2, Table B 3/4.4-1, cataloging the reactor vessel components and critical information and data.
'
4.5 Fuel Storage The' change addressed the addition of the high density fuel racks and
changed the storage capacity from 196' to 1969 fuel assemblies.
!
4.6 Charging Header Pressure - Low The change provided the new charging header pressure-low channel to
!
the TS as a containment isolation system, t
4.7 Chemical Detection Systems The change increased the setpoint for anhydrous ammonia /amonium hydroxide from 5 ppm or less to 25 ppm or less and decreased the system response time from 25 seconds to 5 seconds.
'
,
t The requested changes appeared to be clear.
The inspector nad no significant questions regarding the requested changes to the STP Unit 1
.
and Unit 2 TS. No violations or deviations were identified in the review i
of this program area.
l S.
Emergency Operating Procedures (42452)
5.1 Purpose The purpose of the inspection was to ascertain whether STP Unit 2
.
emergency operating procedures (EOPs) are prepared to adequately
'
control safety-related functions in the event of system or component malfunctions.
.
-
- - -
--
,c-
-, -..
- + -.
<- -
.
. _.
. _ -
.
.
.
-
.
..
,
-12-5.2 Procedures Reviewed The following STP procedures were reviewed during this inspection:
OPGP03-ZA-0002, Revision 13 "Plant Procedures"
OPGP03-ZA-0027, Revisions 3 and 4, "Emergency Operating Procedures Preparation, Approval, Implementation, and Revision"
OPOP01-ZA-0006, Revisions 3 and 4, "Emergency Procedures Writers Guide and Verification"
2 POP 04-CV-0003, Revision 0, "Emergency Boration" 2 POP 05-E0-ES00, Revision 0, "Rediagnosis"
2P0P05-E0-FRH2, Revision 0, "Response to Steam Generator Overpressure"
2 POP 05-E0-FRH4, Revision 0, "Response to Loss of rionnal Steam Release Lpabilities"
2 POP 05-E0-FRHS, Revision 0, "Response to Steam Generator Low Level" 5.3 Status of E0P Completion During the inspection of Unit 2 procedures, 4 of 49 E0Ps and 1 of 41 off normal procedures were reviewed.
Currently 12 of 49 E0Ps had been approved, including 7 that were approved during the time frame of the inspection. All remaining Unit 2 E0Ps were scheduled to be completed, approved, and implemented by October 31, 1988.
A comparison of the current STP Unit 2 E0P index to the Westinghouse Owner's Group Emergency Response Guidelines (WOG EkG) index was performed.
All required ERGS were reflected in the E0P index, indicating that all E0is had been or will be prepared and approved for all WOG FRGs, with one exception.
Procedure 2 POP 05-E0-ES05,
"Natural Circulation Cooldown Without Letdown," was not in the WOG ERGS. The plant specific technical guidelines (PSTGs) for this procedure were developed by Westinghouse and were briefly reviewed by the NRC inspectors.
The STP Unit 2 E0P and off normal procedure indexes were compared to the "Procedures for Combating Emergencies and Other Significant Events" section of Regulatory Guide 1.33, Revision 2, "QA Program Requirements (Operation)." No discrepancies were identified between the indexes and Regulatory Guide 1.3 *
.
,.,..
,
-12-5.4 Plant Specific Values The plant specific values in the E0Ps reviewed were compared to calculations in the E0P Setpoint Document, Revision 2.
No problems or discrepancies were observed between the plant specific values used in the E0Ps and the setpoint document values.
5.5 Technical Adequacy of E0Ps The NRC inspectors assessed E0P technical adequacy by comparing the E0PS to the WOG ERGS and piping and instrument diagrams. A physical walkdown of the procedures was performed to compare the procedure to l
as-built plant conditions.
During tne review, numerous typographical l
and editorial errors were observed to be in the E0Ps. The e:rors by
!
E0P included:
l 2 POP 05-E0-ES00: Wrong procedure title in Step 4.0, and valve
'
number error in Addendum 3 l
l 2 POP 05-E0-FRH2:
Valve number errors in Steps 2.2 and 4.4.
'
Oelete word "contr" from Step 4.2.2 to agree with Step 7.0.b.2
2 POP 05-E0-FRH4: Wrong power supplies listed in Step 1.1, wrong switch position title in Step 1.2.1, and power su missing from Step 1.1.c (secondary operator copy)pply breakers
2 POP 05-E0-FRH5: Wrong valve numbers in Step 4.1.a.2, wrong pressure indicators listed in Step 3.1.2, panel location and nameplate engraving missing from valves listed in Step 4.1.c.
'
contingency action missing from Step 3.1.2 of secondary operator j
copy, and primary and alternate indications in Step 4.0 of secondary operator copy reversed 2POPO4-CV-0003: Title of Section 4.0 incorrect in Step 1.2.2, a
and nameplate engravings incorrect in Steps 4.1.1, 5.1, and 5.2 Because of the types of errors identified, the NRC staff will conduct an additional E0? team inspection in the imediate future. This area
,
i will be treated as an unresolved item (498/8852-02; 499/8852-02) pending the additional inspection.
l l
5.6 Deviations from WOG ERGS One of the areas included during the comparison of E0Ps to ERGS was to note deviations from the generic guideliner. (ERGS) and to i
determine if the identified deviations were properly justified and l
documented.
l All Unit 2 E0Ps were developed from Unit 1 E0Ps.
The documentation i
of deviations from ERGS was included in Unit 1 E0P packages, but not Unit 2 E0P packages.
Therefore, the review of Unit 2 E0P deviations was performed using Unit I documentation packages.
l
-
.
'
.'
..
,.
.c
,
-13-Several justifications for apparent deviations from the ERGS could not be located, including:
In 2 POP 05-E0-ES00, Conditional Information page the "AFW
Supply" section was not in agreement with the EEG's.
In 2 POP 05-E0-FRH2, Step 4.4, the additioial step to open the
HSIV above seat drain valves was not included in the Ek3s.
In 2 POP 05-E0-FRH4, Step 2.0, "Contingency Action," the ERG's
wording implied instructions to open the PORVs.
This step was not included in the E0P.
In accordance with OPOP01-ZA-0006, the E0P step justification /
verification form was used to document deviations from the ERGS.
During the review of Unit 1 E0P packages, it was observed some deviation justifications were incorporated into the E0P packages using reviewer comment forms. The resolution section of the E0P discrepancy /coment form provided information or a response that was incorpo.'sted into the FOPS.
The infonnation incorporated into the E0Ps resulted in or j..;ified EPG deviations.
For example, a coment
!
was made about Step 1, Note 1, of ERG ES-0.0.
The resolution section of the comment form tried to justify why the note was not present in 2 POP 05-E0-ES00.
(EOPste be located for this item)p justification / verification form could not A second example was a coment on the use of the words "not faulted" versus "intact" to oeo:*ibe steam generator integrity in 2 POP 05-E0-ES00.
The ERGS useo ar,i defined the word "faulted," while the E0PS used the word "intact." ~ The use of coment forms to justify ERG deviations was.not the intent of Steps ?.2 and 2.3 of OPOP01-ZA-0006.
The causes of unjustified or inadequately justified deviations from the ERGS noted by the NRC inspectors indicated apparent programatic weaknesses, as demonstrated by the following:
Deviations were going unidentified and uncorrected through
several levels of review, including PORC and QA reviews.
<
E0P procedure writers may not have recognized the significance
of the deviation or correct method of documenting deviations.
The technical basis documents (ERGS and associated deviations)
were not easily or adequately accessible.
This could lead to inconsistencies between the basis documents and the E0Ps they support.
Note: An up-to-date, controlled technical basis.is necessary.
r
-. -
. - -
-
. - - -.
- -.
. - - -
- - - - - - - -
. - -
- - - - - -
- -. - -.
-
.
-
-
...
- -. -
- -.. -
- -
-
-
- - -
- -
-.. -
-
_-
.
-
_
.
,
..
'
'
,,,..
'
-14-
,
,
,
The lack of. documentatinn suppcetins fations from the WOG ERGS was also reported in NRC Inspection Repi 30-498/87-08; 50-499/87-08
'
(498/8708-61), which is currently st 1 open. -This concern-was discussed with.the licensee and 'he licensee stated all-justification forms for deviations from ERGS will be compiled.into an easily
auditable' fonn by Unit 2 fuel load and the review and documentation
,
of o?1 deviation. justifications will be completed prior to the first refueling outage.for Unit 1.
S.7 Writers Guide Compliance c
-
,
As part of the~ review, the E0Ps were compared to the requirements
'
given in OPOP01-ZA-0006. "EOP Writers Guide and Verification.".Two -
discrepancies were noted:
,
,
The use of asterisks (*) to denote safet'y-related equipment was
required by Step 7.3.
Unit 1 E0Ps used asterisks,, hut Unit 2
E0Ps did not.
Step 7.3 has since been deleted'by the' licensee.
Brackets ([]) were used in the E0Ps when specifying adverse
containment values. This was in' disagreement with Section 14.3 and 6.14 of the writers guide. The licensee corrected Ste,9 14.3
during a recent revision of OPOPC1-ZA-0006, but Step 6.14
'
required revision to change the word "parenthesis" to
"brackets."
i 5.8 Verification and Validation Process'
'
s The verification and validation (V&V) process of E0Ps was reviewed.
.
The Unit 2 E0Ps were converted from Unit 1 proceddres, using guidelines given in Procedure OPGP03-ZA-0002. !! nit 1 E0Ps were
'
,
reviewed, verified, and validated using guidelines given in
-
i Procedure OPGP03-ZA-0027. The level of review, as well as V&V, of
Unit 2 E0Ps was less stringent using guidelines given in
,
,
OPGP03-ZA-0002. However, the guidelines of OPGP03-ZA-0027 applied to
both Unit 1 and Unit 2 procedures; therefore, a conflict existed
'
between OPGP03-ZA-0027 and OPGP03-ZA-0002. The licensee revised OPGP03-ZA-0027 during the time interval of the inspection to clearly l
state how Unit 1 E0Ps would be converted to Unit 2 procedures, and
how Unit 2 procedures would be reviewed.
<
j A comparison of Unit 2 E0P errors and discre)ancies were compared to j
the same E0Ps for Unit 1.
It was observed t1at most errors were also
{
found in tha Unit 1 procedures.
This observation indicated the
]
original V&V done on Unit 1 procedures was weak or the procedures
,
stere inadequately proof-reviewed between revisions. The carryover of
<
Unit 1 E0P errors into the Unit 2 E0Ps indicated thr. Unit 2
'
i conversion and review process was weak.
These errors also went undetected during the TS required PORC and the quality assurance
,
reviews.
)
!
.
-
..
-
-
-
.
. -
-
-
-
-
-
-. -
- -
-
- -.
.
.
.
.. *
..
,
-15-
-
The licensee provided infomation on how the Unit 2 E0P walkdowns will be upgraded, and that an independent editorial review will be performed on all E0Ps.
The licensee also stated Unit 1 E0Ps will be reverified by walkdown by December 31, 1988. Other areas of the V8V process that required further licensee consideration were design engineering and human factor specialist reviews.
"Guidelines for the Preparation of E0Ps," Step 3.3.4, states,
"Because of the variety of infonnation and skills needed, writing the E0P requires a team approach.
The team skills should include, but iiot be limited to, technical writing, human factors, power plant operation, operator training, and engineering design." The NRC noted that design engineers should review E0Ps tc ensure an engineering analysis is performed.
In order to address this concern the licensee responded by adding the Support (design), Nuclear and Plant Engineering de artmen':s in the review process (Step 5.3 of OPGP03-ZA-0027.
However, the human factor specialist involvemenc in the E0P development was found to be minimal.
NUREG 0737, Supplement No. 1 Step 7.1.a states, "The use of human factored, function orientd'i, emergency operating procedures will improve human reliability and the ability to mitigate the consequence of a broad range of initiating events and subsequent multiple failures or operator errors, without the need to diagnose specific events."
The E0Ps in use at STP have not been given a rigorous human factors
.
review to ensure the E0Ps were clear, organized and consistent with
'
the writers guide.
Punding licensee response, this will be tracked as an open item (498/8852-03; 499/8852-03).
5.9 Other Areas Inspected 5.5.1 Section 6.2.3 of NUREG 0899 states, "Licensees and applicants should consider establishing a program for the ongoing evaluation of the E0Ps." The STP E0Ps will be reviewed by the licensee as required by Procedure OPGP03-ZA-0010
"Plant Procedure Compliance Implementation and Review."
,
'
The licensee will perform a review on a biennial basis, using the procedure biennial review form and associated checklist.
5.9.2 Theoriginalproceduresgenerationpackage(PGP) submitted to the NRC, and responses to NRC comments on the PGP, were reviewed by the NRC inspectors.
It was noted the licensee does not have a unique PSTG, but developed the E0Ps directly from the WOG ERGS. One exception was 2 POP 05-E0-ES05,
"Natural Circulation Cooldown Without Letdown." This procedure was not found in the WOG ERGS index, but a PSTG for the procedure was reviewed (South Texas Safety Grade Cold Shutdown / Fire Hazards Operational Evaluation Report, Appendix B ES-0.5, Revision 2, dated March 31,1987).
.
_
.
.
.
_- -
-
.
'
"
...
,,
,
-16-5.9.3 During the review of the responses to NRC comments on the PGP (HL&P letter ST-HL-AE-1848), thrae HL&P responses appeared not to be incorporated as committed:
B.16.c response - revising writers guide to specif method of location aids for addendums to tne E0Ps.y
B.18.a response - revising writers guide to reflect requirement to underline headings in E0Ps.
- C.1 response - revise OPGP03-ZA-0027 to include Suman factors experts to be a component of the future validation team (s).
Pending licensee resolution, the above deficiencies will be tracked as an open item (498/8652-04; 499/8852-04).
5.9.4 A program to check E0P revisions to the basis documents (WOG ERGS and their associated deviations) should be clearly stated in OPGP03-ZA-0027. Changes in setpoints, instrumentation or plant equipment should be compared to the basis documents for potential effects on the E0Ps.
If the E0P revision process is not controlled carefully, the situation where E0Ps could degrade in quality and technical accuracy may occur.
As stated previously, the licensee does not have a unique PSTG. A comittment was made by the licensee to compile justifications for deviations from the WOG ERGS into an easily auditable form prior to Unit 2 fuel load. This
"document" will resemble a PSTG and should be controlled.
This document, as well as any other document included in the technical guidelines, should be audited by the QA organization on a regular basis (in accordance with comitments to Regulatory Guide 1.33/ ANSI N18.7-1976/ANS-3.2).
5.9.5 NUREG 0S99, Step 4.4, states, "As a primary basis of plant E0Ps, PSTG should be subject to examination under the plants overall QA program (see Regulatory Guide 1.33).
Licensee and applicants are responsible for ensuring that its technical guidelines are accurate and up to date.
Thus, review and control of the technical guidelines should be included in the established QA program."
5.10 Sunnary During the review of this program area (EOPs), no violations or deviations were identified.
Two unresolved items were identifie,
l
i
'
,,,..
,
-17-6.
Unresolved Item Unresolved items are matters about which more information is reqired in
,
order to ascertain whether or not the items are acceptable, violations, or deviations. The following two unresolved items were discussed in this report:
Paragraph Item Subject 3.2.2 and 498/8852-01; Independent inspection of critical 3.3.1 498/8852-01 characteristics
!
5.5 498/8852-02; E0P errors 498/8852-02 7.
gnagementExit The NRC inspectors sumarized the scope and findings associated with the inspection, includin changes (continuing)g the review of Unit 2 maintenance proceoures, TS
, and emergency operating nrocedures.
The licensee disagreed with the NRC inspectors' coment regarding the
,
apparent lack of quality inspection points wi_ thin the specific detailed maintenance procedures. However, the. licensee agreed to look at the i
expressed concern objectively.
The licensee review and approval of the remaining Unit 2 procedures was
reviewed in general. The NRC inspectors noted that substantial number of procedures remained to be completed and noted the need to maintain the quality of the procedures during the heavy workload period. The licensee acknowledged the coment.
During the exit interview, the scope of the findings on E0Ps were presented to the licensee. The failure to incorporate comitments (paragraph 5.9.3)
t was reported as an apparent deviation.
The apparent deviation was later determined to be an open item, since plant safety had not been compromised
,
by the failure of tne license to incorporate the comitments.
The technical adequacy section (5.5) of E0Ps was reported to the licensee as an open item.
The open item was upgraded to an unresolved item when the issue was reviewed by NRC management.
The licensee was later notified (September 30,1988) by telephone of the NRCs concern in this area and the scheduled E0P team inspection.
I The licensee did not identify as proprietary any of the material provided to or reviewed by the NRC inspectors during the inspection.
i
.
.
.
.
.