IR 05000498/1989001

Insp Repts 50-498/89-01 & 50-499/89-01 on 890109-13 & 23-27. No Violations or Deviations Noted.Major Areas Inspected: Calibr Program & Preventive Maint Program Re Calibr of Plant Instrumentation for Components Not Addressed in Tech Spec

ML20236C476
Person / Time
Site:	South Texas
Issue date:	03/09/1989
From:	Andrea Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236C472	List: IR 05000498/1989001 ML20236C468
References
50-498-89-01, 50-498-89-1, 50-499-89-01, 50-499-89-1, NUDOCS 8903220173
Download: ML20236C476 (9)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

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L REGION IV i NRC Inspection Report: 50-498/89-01 Operating Licenses: NPF-76 .,

50-499/89-01 NPF-78 j

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. Dockets: 50-498 l _50-499 l ' Licensee: Houston Lighting & Power Company (HL&P) Ll

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P.O. Box 1700 Houston, Texas 77001

Facility Name: South Texas Project, Units I and 2'(STP) l i

Inspection At: STP, Matagorda County, Texas Inspection Conducted: January 9-13 and 23-27, 1989 Inspector: /\ d ) A A. R. Jbhnson, Reactor IMspector, Plant Systems Sk/M Date y

Section Division of Reactor Safety'

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i Approved: Mffik $ [9!'[rf T. Stetta, Chief, Plant Systems Section Date <

Division of Reactor Safety

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Inspection Summary *

Inspection Conducted January 9-13 and 23-27, 1989 (Report 50-498/89-01)

~ Areas Inspected: Routine, unannounced inspection of the licensee's Technical 4 Specification (TS) required calibration program, and the preventive

,. maintenance (PM) program related to the calibration of plant instrumentation

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for components not addressed in the T Results: Within the areas inspected, no violations or deviations were

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identifie The licensee's plant surveillance (PS) calibration program for the control and evaluation of installed instrumentation and control (IAC) devices, specified by the TS is effectively being implemented and no weaknesses were note '

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-2-An apparent weakness was identified, however, in the licensee's calibration program for I&C devices not addressed in the TS. The apparent weakness involves a lack of procedural controls which resulted in a large number of installed I&C device calibration deferrals. This issue has been identified as an .aresolved ite Inspection Conducted January 9-13 and 23-27, 1989 (Report 50-499/89-01)

Areas Inspected: No inspection of Unit 2 was conducte Results: Not applicabl . . . . _____ _ _ _ _

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I DETAILS Persons Contacted l

HL&P_

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• • W..H. Kinsey, Plant Manager .

• • M. R. Wisenburg, Plant Superintendent ~, Unit 1-

• • S. L..Rosen, General Manager,. Operations Support .

• • S. M. Dew, Manager, Operations Support  !

• • G. E. Vaughn, V.P. Nuclear Operations l

• • M. A. McBurnett, Licensing Manager

• P. L. Walker, Senior Licensing Engineer l

• K. L. Trippel, Lead Engineer i

• Fast, Instrumentation & Control (ISC) Maintenance

• M. Head, Supervisor, Licensing Engineering

• • J. Jump, Maintenance Manager

• • H. Carney, I&C Supervisor

• • J. L. Lewis, I&C Technical Supervisor . .

• • S. E. Hill, Maintenance Support Administrative Supervisor

• • R. A. Ferguson, Licensing Engineer . -

• • W. P. Morgan, Manager, Materials Laboratory J. E. Noftsger, I&C. Technical Supervisor W. H. Humble, Programs Supervisor R. Grantom, I&C Technical Department J. Wallace, Outage Department i J. Geiger, General Manager, Nuclear Assurance .l R. Balcom Quality Assurance, Operations

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NRC

• • J. E. Bess, Senior Resident Inspector, Unit'1'

• • R. J. Evans, Resident Inspector, Unit 1 - ,

• Attended exit interview on January,13, 198 ** Attended exit interview on January ~27,:198 The NRC inspector contacted other licensee personnel during the inspection, i Calibration of Plant Instrumentation (56700)

This inspection was to accertain whether the licensee had developed and .

implemented a program for the calibration and testing of plant installed I I&C devices. This includes the I&C devices specified in the Technical'

Specification (TS) and-I&C devices that are used for the operation and testin of equipment but not specifically addressed in the TS as requ' iring !

calibratio l

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2.1 Calibrations Specified by TS Calibrations required by TS are controlled as part of the STP Plant Surveillance (PS) Program. The inspection determined.that procedures for calibration of plant . installed I&C devices, specified by.TS, are being implemented in accordance with the calibration program administrative- i

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controls, as prescribed by the STP FS/.R. Sections 7.0 and 17.2, and related commitments to Regulatory Guides and Standards. The TS surveillance program data base is well established and re flects .the status.of. all planned 'in-plant surveillance tests and inspections. This schedule.is outlined in STP

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Operations QA Plan - Instrumentation and Calibration Control (QAP), .

l-Section 12, phragraph 6.1, and STP Plant Procedures Manual .(PPM) 1 l

OPG P03-ZM-0016, Revision Technical Specification surveillance and

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calibration requirements'are further controlled by Procedure OPG P03-ZE-0004, Revision 2, and together with the QAP include requirements- that verify ..

completion of, surveillance tests.and inspections required by the T )

The NRC inspector verified that installed I&C device channel calibrations (CCs), analog channel operational tests (ACOTs), trip l actuating device operational tests (TAD 0Ts), actuation logic tests (ALTs),

master / slave relay tests (MRTs/SRTs), and response time tests (RTTs),

specified by the TS were performed.at the required frequencies. The NRC inspector used the TS Surveillance Program Data Base for STP-1 dated January 11, 1989.

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l The NRC inspector examined completed test and calibration procedures (documentation packages) for surveillance performed during the last 18 months. This review verifiedi (1) test documentation was complete; (2) approved procedures were utilized; (3) acceptance criteria were met; (4) performance was in accordance with the procedures; and (5) completed procedures contained "as found" conditions. The specific documentation packages examined by the NRC' inspector are listed below:

Engineered Safety Features Actuation System (ESFAS) Instrumentation

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Surveillance Requirements Procedure N Revision N . Title 1 PSP 02-SP-0004-1 0 ESF Manual Initiation, TADOT 1 PSP 03-SP-0005R 0 SSPS Train Logic, Train R ALT IPSP03-SP-0007A-1 0 SSPS Train A, MRT IPSP03-SP-0008A-1 0 SSPS Train A, SRT 1 PSP 05-RC-0455-1 0 Pressurizer Pressure Set 1. CC 1 PSP 02-RC-0455-1 2 Pressurizer Pressure Set 1, ACOT

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-5-IPSP05-MS-0514-1 1 Steam Pressure Loop 1 Set 1, CC IPSP02-MS-0544-1 3 Steam Pressure Loop 4 Set 1, ACOT IPSP02-MS-0524-1 3 Steam Pressure Loop 2 Set 1, ACOT 1 PSP 02-HC-0936-1 1 Containment Pressure Set 2, ACOT IPSP05-HC-0935-1 0 -Containment Pressure Set 3, CC 1-SP-P-03 0 Solid State Protection System, RTT, Credit Package (for 1 PSP 13-HC-0934, 0935, & 0936)

1-SP-P-03 0 Solid State Protection System, RTT, Credit Package (for IPSP13-RC-0465, 0466, 0467,

& 0468)

Reactor Trip System (RTS) Instrumentation Surveillance Requirements Procedure N Revision N Title 1 PSP 02-RC-0420-1 2 Delta T and T Average Loop 2 Set 2, ACOT IPSP05-RC-0410-1 0 Delta T and T Average Loop 1 Set 1, CC 1 PSP 02-RC-0465 1 2 Pressurizer Level Set 1, ACOT IPSP05-RC-0465-1 1 Pressurizer Level Set 1, CC IPSP02-RC-0481-1 3 RCS Flow Loop 1, Set 2, ACOT 1 PSP 05-RC-0418-1 1 RCS Flow Loop 1, Set 2, CC IPSP03-SP-0006R-1 0 Train R Reactor Trip Breaker, TAD 0T The NRC inspector made the following observations with regards to the licensee's PS program:

2. RTT Procedures Data packages were prepared by HL&P, using preoperational test data prior to station startup of STP-1, in lieu of RTT requirements by T Many RTT procedures for frequencies of 18-months and greater, have l not yet been issued. At the tine of this inspection, 207 out of I

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'- 6-approximately 1000 RTT procedures still remain in draft form. These procedures will be issued at STP-1 prior to the first TS required RTT perio . CC Procedures Preoperational test data packages for STP-1 were used in lieu of. CC procedures to meet initial CC surveillance requirements. The CC surveillance were short-period calibrations which have since been  !

accomplished using newly issued CC procedures. The NRC inspector estimated that 10 percent of STP-1 CC surveillance were performed, taking credit for test data package . ACOT, TADOT, ALT, MRT, and SRT Procedures All initial and' subsequent ACOTs, TAD 0Ts, ALTs, MRTs, and SRTs-for STP-1 are being. accomplished using issued surveillance procedures.

, No' violations or deviations were identifie .2 Calibrations Not Specified by TS The programmatic controls for the calibration of installed I&C devices used at STP for safety-related/ quality-related applications, associated: 4

, but not addressed in the TS, are part of the STP preventive maintenance (PM) <

l Program. These instruments are used during surveillance testing and -

operation of safety-related equipment and are referred to in the STP plant routine operating procedures. The schedule of calibration and verification

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for these insta11ed'I&C devices is outlined in the STP QAP, Section 12 and l

Procedure No. OPGP03-ZM-0002, Revision 16. "PM Program."

HL&P has accomplished an engineering review of some 7000 safety-related/

quality-related instrument devices to determine their requirements with regards to PM calibration activities. HL&P has established an approved and active PM list of approximately 1500 instrument devices based on the following criteria:

HL&P reviewed the Architect Engineer's (Bechtel's) instrument index l and included safety-related instrument classification groups on the approved PM lis HL&P reviewed all STP routine operating and surveillance procedures and included all instruments contained in these procedures on the '

approved PM lis *

HL&P accomplished an engineering review of the STP main control room and included all these instruments on the approved PM lis ,

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The.NRC inspector reviewed the licensee's implementation of Procedure OPGP03-ZM-0002 to ascertain whether calibration of'the, selected-

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instrument devices in the.PM program were~being accomplished effectivel The NRC inspector reviewed the licensee's PM Schedule. Data Base,Ldated ,

January 25, 1989.' The data base.is used by HL&P to prioritize:the scope and frequency of the required PM calibration activities. - The NRC -

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inspector. sampled PM data packages listed on the data base-for:: .

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(1) backlog of past due calibrations; (2) reasons' for deferrals, inactivations,.and cancellations; (3) availability of approved procedures.

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for calibration of instrument devices; and.(4) examination of technical content. The sample PM data packages were limited to instrument device calibrations performed by the maintenance. I&C division. - The- followingL is a list of PM procedures reviewed: 4 PM N Description Fre- Due - Da'te quency Fate TerTormed (Weeks)

IC-1-AS86011921= Calibration, Aux Steam 26 05/29/89 10/14/88 '

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To LWPS, HELB A Protection (Tag #A1ASPDSH8838A)

IC-1-CH-86009893 Calibration, ECHW Train A, 24' 05/01/87 *

Chiller VCH004, Compressor Discharge (Tag # NICHPI9504B)

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I IC-1-CH-86009895 Calibration, ECHW Train A, 24 01/27/89 07/01/88 i l Chiller VCH004, Compressor 1 1 Suction Pressure l (Tag # NICHPI9504A)

IC-1-CH-86009896 Calibration, ECHW Train A, 24 .05/01/8 * f

. Chiller VCH004, Compressor Lube Oil Pressure (Tag # NICHPI9504)

IC-1-CH-86009900 Calibration ECHW Train C, 24: 02/07/89 07/12/88 Chiller VCH006, Compressor Lube Oil Pressure (Tag # NICHPI9516)

fC-1-CH-86009902 Calibration, ECHW Train C, 24 02/07/89 07/12/88 ~ '

Chiller VCH006, Compressor

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Suction (Tag # NICHPI9516A)

l- IC-1-CH-86009903 Calibration. ECHW Train C,~.24 02/07/89 07/12/88 Chiller VCH006,' Compressor Discharge Pressure (Tag #NICHPI9516B)  ;

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'IC-1-CH-86009909- Calibration, ECHW Train B, 24 12/01/88 05/05/88 Chiller VCH005, Compressor Lube Oil Pressure

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(Tag # NICHPI95108)

.IC-1-CH-86009911 Calibration, ECHW Train B, 24 -12/01/88 05/05/88 Chiller VCH005, Compressor Suction Pressure (Tag # NICHPI9510A)-

L TC-1-CH-86009913 Calibration ECHW Train B, 24 12/01/88 05/05/88-Chiller VCH005, Compressor.

l Discharge Pressure (Tag # NICHP19510)

1C-1-CH-87011946- Calibration, Mild 26 02/13/89- -*

Environment, ECHW Train A, Chiller.VCH004, Purge High-Pressure (Tag # AICHPSH9533)

IC-1-CH-87011947 Calibration, Mild '26 06/09/89 10/25/88 Environment, ECHW Train B, l Chiller VCH005, Purge High l Pressure (Teg # B1CHPSH9534)

Calibration, ECHW Train A,

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IC-1-CH-87014078 *

45 07/04/88 Chiller VCH004, 011 Heater-Thermostat (Tag #A1CHTSH9435)-

l IC-1-CH-87014080- Calibration, ECHW Train C, .45 12/22/88 *

l Chiller'VCH006, 011 Heater Temperature (Tag # ICHTSH9437)

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l IC-1-DG-86003021 Calibration, Diesel 78 03/27/88 * i Generator #11, Engine 1 Speed (Tag # AIDGSI5476B)

-IC-1-D0-86007536 Calibration, Diesel *

78 03/27/8 Generator #11, Fuel Oil Drain Tank (Tag # AIDOLSHL5470)

IC-1-EW-86002645 Calibration, Diesel 78 06/24/88- *

Generator Heat Exchanger Outlet Temperature, Train A .

'(Tag # A1EWFT6855)

IC-1-EW-86003348- ' Calibration, CCW Pump 78 '09/23/88 *

Cooler Outlet, Train A (Tag # A1EWFT6856)

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TC-1-MS-860011155 Calibration, Steam: . 78 ;10/04/89 *- 1 Generator-ID, PORV High )

Hydraulic Pressure .1 (Tag'f 01MSPSH7441) 1

IC-1-MS-86011156 Calibration. Steam -78 -10/04/89

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Generator ID P Low l Hydraulic Pressure ,

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ODenotes not' performed ye *

The NRC inspector determined that' the PM' data' packages were complete; .

i acceptance criteria had been met; the proper approved test procedures.had been 1 l

used; and technical contents were-acceptable.- However, the.NRC inspector 1 noted that many calibrations.had exceeded their due dates and still required:

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L performance. The backlog _of past.due calibrations appeared to.be-a' result ~

of inadequate procedural controls atiSTP resulting,in a(failure to meet .

required calibration frequencies as outlined by Procedure OPGP03-ZM-000 The NRC inspector discussed the backlog of past 'due calibrations; problem with, the licensee and determined that the-licensee had identified this issue and {

was in the process of taking appropriate and timely corrective action. This

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issue is considered to be an unresolved: item ~pending. correction by the

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Unresolved Item (498/8901-.01): . Complete corrective. actions.to pr' event overdue calibrations of instrumentation not specified by the T ~ Exit Interview i

The inspection scope and findings were. summarized on January 27, 1989, with the licensee personnel indicated in paragraph 1 above. The licensee did not identify as proprietary any of the materials:provided to or reviewed by the NRC inspectors during the-inspection.

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