IR 05000498/1989015

Insp Repts 50-498/89-15 & 50-499/89-15 on 890607-30. Violations Noted.Major Areas Inspected:Followup of Previous Insp Findings,Operations Procedures & Two Amends to Tech Specs

ML20245J531
Person / Time
Site:	South Texas
Issue date:	08/03/1989
From:	Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245J525	List: IR 05000498/1989015 ML20245J521 ML20245J528
References
50-498-89-15, 50-499-89-15, NUDOCS 8908180060
Download: ML20245J531 (29)

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APPENDIX B U;S; NUCLEAR REGULATORY COMMISSION

REGION IV

NRC-Inspection Report: 50-498/89-15 Operating Licenses: NPF-76 50-499/89-15 NPF-80 Dockets: 50-498 50-499 Licensee: Houston Lighting &' Power Company (HL&P).

P.O. Box 1700 Houston. Texas '77001

Facility Name: South Texas Project '(STP) Electric Generating Station, Units 1 and 2 Inspection At: STP, Wadsworth (Matagorda County), Texas Inspection Conducted: June 7-30 1989 Inspector: -. - _, t f>L___ . J p D.' R. Eunter, Senior Reactor Inspector Datf

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Operational Programs Section, Division of Reactor Safety

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Accompanying Personnel: R. Jones, Instructor Training, PWR Section Technical Training Center (June 12-16,1989)

Approved: / t< a dgliardo, Cfiief, Operational Programs D6te'

[. f.ect on, Division of Reactor Safety Inspection Summary Inspection Conducted June 7-30, 1989 (Report 50-498/89-15; 50-499/89-15)

Areas Inspected: Routine, announced inspection of the followup of previously l identified inspection findings, operations procedures, and two amendments to the Technical Specification Results: Within the three areas inspected, one violation was identifled (inadequate abnormal operating procedures, paragraph 3.4.6).

8908180060 890810 98 ADOCK 0500 gDR

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rocedures at STP appeared to be-The acceptable;loverallhowever, programin regarding the. area ofsafety-related

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abnormal:. p(annunciator and off-normal) -

- procedures, the lack-of'adsquate procedures was*1dentified (scope and content).

iThe, licensee was depdnding heavily on the licensed operator's basic knowledg s .i .olevelf in ~orde'r to respond to abnormal plant ' transients. The licensee apparently f !had:not fully l assessed the procedures for abnormal plant transients at ST _[. ' q ( .

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DETAILS 1.0 Personnel Contacted HL&P

• W. H. Kinsey, Plant Manager

+ G. E. Vaughn, Vice President, Nuclear Operations

+ R. W. Chewning, Vice President, Nuclear Assurance

+*J. E. Geiger, General Manager, Nuclear Assurance r R..L. Balcom, Manager, Quality Assurance Audits

'R..Erickson, Supervisor, Quality Assurance Audits

+ M. A. Ludwig, Manager, Materials Management

+ W. J. Jump, Manager,-Maintenance

+*M. R. Wisenburg, Plant Superintendent

+*M. A. McBurnett, Licensing Manager

• W. S. Blair, Manager, Maintenance Support ~

+*J. W. Loesch, Plant Operations _ Manager

++T. J. Jordan, Plant Engineering Manager

+*V. A. Simonis, Plant Operations Support Manager

• R. L. Prater Procedure Coordinator, Maintenance

'*S. M. Head, Supervisor, License Engineering

+ A. C. McIntyre, Manager Support Engineering

+ W. W. Perry. Manager Electrical Maintenance

+-C. T. Bowman, Plant 0perations Supervisor

• P. L. Walker,' Senior Licensing Engineer

+ S. M. Dew, Manager, Mechanical Maintenance

+ D. W. Bohner, Plant Quality Engineering Supervisor

+ K. L. Gustafson, Supervisor, Records Management D. LeGrand, Unit Supervisor, Operations M. Felix, Unit Supervisor, Operations Other

+ R. L. Scott, Licensing Engineer

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+*J. Neeley, Engineer, City of Austin L

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+ J. E. Bess, Senior Resident Inspector l *R. J. Evans, Resident Inspector

• J. I. Tapia, Senior Resident Inspector

+ Denotes those attending the management exit meeting on June 16, 1989.

• Denotes those attending the management exit meeting on June 30, 1989.

l Other licensee personnel were contacted during the inspection.

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i 2.0.-Followup on Previously Identified Inspection Findings

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The inspector reviewed the actions taken by the licensee regarding the following previously identified inspection findings:  ;

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2.1 ' Violations - Deviations (92702)

2. (Closed)' Violation (498/8846-01; 499/8846-01) - Procedures / Instructions for Quality Activities: The inspector reviewed the licensee. corrective actions outlined in STP response'(ST-HL-AE-2901) to the violation s dated December 14, 1988. Items selected for review included:

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Maintenance Work Request, MWR-HE-65094, dated July 27,19538, to replace the missing cover to the battery room heater E1C11. The battery room heater cover was replaced on July 27, 1988. The:

licensee decided to not torque the cover bolt *

Plant Procedure OPGP03-ZM-0003, " Maintenance Work Request

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Program " Revision 20, dated September 29, 1988, addressed the notification of the original supervisor when voiding an MWR (step 4.6.1.3, Revision 19); the review of voided MWRs and-routing to records management for retention (step 4.6.1.4, Revision 19); the requirement'to complete an MWR;or the deletion of the MWR in accordance with the procedure (step 4.12.16 Revision 19); and a statement regarding area cleanliness, tool storage, and hardware restoration requirements (Addendum 10, Item 10).

Maintenance personnel had been trained on Procedure OPGP03-ZM-0003 (October 28,1988).

Maintenance crews had been briefed regarding the importance of area cleanliness, tool removal, and hardware restoratio The Unit 1 building walkdowns were completed and seven work requests were issued associated with the buildings. Interviews and document review revealed the Unit i reactor containment building was also walked down during an unscheduled outage. The work associated with four of the seven building work requests had been completed and the other three work requests, including the Unit I reactor containment building were scheduled to be completed prior to the end of the scheduled refueling outage (September 1989).

The Unit 2 building walkdowns were completed and the findings dispositioned as part of each building turnover to the production from r. constructio __ _

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' The licensee had revised the Nuclear Group Policy, NGP-250,'"HL&P -

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. Responsibility for. Physical Work _ Performed on Operations Units." '

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The inspector had no further questions regarding this matte ~

, 1-Th'is violation is considered close .3 - s

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" -(Closed) Violation (498/8854-02;499/8854-02)- Inadequate Off-N'ormal 2.' procedures: The inspector reviewed the licensee response (ST-HL-AE-2874) m

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to the violation dated November 18, 1988, and the supporting documentatio 'The following selected information was reviewed:-

A' memorandum was issued to the shift supervisors, dated-November'18. 1988,'for training purposes to' reenforce to the'

shift' operating crews 'that references in the' procedures to the Technical: Specifications (TS) require.that the required actions -

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of the TS were to be taken. The memorandum requested that the-

. attached attendance sheets be completed and forwarded to a specified individual, cThe records.of the on-shift training were not recovered by the licensee. The inspector discussed the matter with the licensee and interviewed selected personnel to ensure that the philosophy contained in the letter was understood. Furthermore, a walkdown of the off-normal procedures and a procedure review had been completed by.the licensee in th fall of 1988. The off-normal procedures were upgrade *'

The licensee perfonned off-normal procedure and plant labeling walkdowns and identified a number of deficiencies' requiring

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prompt corrective' action. The deficiencies were identified in a summary report, dated February 24.-1989. The actions were completed on the' units, as appropriate. Interviews and records review revealed that the' Unit 1 procedures and labels were generally acceptable and that almost all the deficiencies occurred in Unit'2. Subsequent reviews and walkdowns of the off-normal procedures in Unit 'I by the licensee did not identify other deficiencies. The procedure enhancement program being'

implemented by the licensee included the review and walkdown of all of the off-normal procedures. The review of the procedures was scheduled to be completed as part of the overall procedure enhancement progra The inspector reviewed an excerpt from the plant Operations-Department monthly report (May 1989, pages 16-18) which provided a status of'the plant labeling program. The licensee had developed a comprehensive program to develop and implement labeling on both unit ,

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The' inspector reviewed Instrument Calibration m . Procedures IPSP05-NI-0041 through 0044 Revision-1. The-

, procedures were revised to. refer to the Power Range Nuclear.

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Instruments Off-Normal Procedure IPOPO4-NI-0003 to trip the: ,

N instrument channels'as appropriat " *

.The. inspector reviewed Procedure OPOP04-RP-0001, " Loss.of'

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Automatic Pressurizer Pressure Control." Revision O and selecte Trevisions'to,the procedure. Step 5.3.1 of the procedure referred .

to TS 3.3.1 for actions regarding the failed instrument channel;- /

however, neither steps'4.2-nor 5.3.1 referred to TS'3.4.4 for

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actions regarding the removal of the power to the closed power' '

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operated relief valve block valve. This deficiency was brough '

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'to the attention of the licensee for evaluation. The licensee-c issued procedure field change No. 89-1613, dated June 14, 1989,

, which added TS 3.3.2 and TS 3.4.4:as references to step 5.3.1 of:

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< the procedure. The inspector interviewed selected ' operations -

<, personnel to ensure that the reference was understood and.that '

the procedure in the control room was curren s

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> ~The failure to revise the procedure as required to encompass the requirements of the TS appeared to be an isolated occurrence, inf

that the other procedure changes were noted to have been-i accomplished and interviews revealed that the operators were aware of the requirement. Therefore, no violation or deviation will~be issued regarding this item.- The inspector had no l

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t :further questions regarding this matte *

Although this violation is considered closed because the-licensee *

.. completed the specific items to which he was-committed to correct t

.it, additional problems with Procedure OPOPO4-RP-0001 were noted and addressed in paragraph .

2. (0 pen) Deviation (498/8805-01;499/8805-01)- Emergency Operating Procedure'(E0P) Upgrade: The deviation concerned the failure to include the utilization of the reactor head vent valves in order to maintain the reactor vessel' head subcooled as committed in a letter

, (ST-HL-AE-1922), dated February 23, 198 The inspector reviewed selected documented licensee corrective actions as stated in the letter (ST-HL-AE-2610) to the NRC dated April 14, 1988. The selected actions reviewed included:

• Licensee interoffice memorandum (ST-HS-HS-10213), dated September 29, 1988, concerning the rereview of approximately 800 letters written during the period from June 1986 to present

. to ensure that commitments were recognized and implemented. The report identified a number of missed commitments and provided recommendations to improve the progra = - - _ ---.

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Interviews of licensee personnel revealed that the missed

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commitments (22) had been reviewed and no safety impact was identified. The' evaluations were not documented and included as

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part of the overall corrective action program for tracking, trending,'and audit purposes. The specific items, however, had been entered on the licensee comitment tracking system and were completed or scheduled for completion.:

The licensee issued Deficiency Report (DR No.89-047) Revision'1, on June 21, 1989, during the inspection, concerning the failure to initiate a Problem Report which would have caused the failed comitments to be fully evaluated and documented and would have considered the initiation of corrective actions to prevent recurrence. The response due date _for the deficiency report was July:21, 198 During the inspection, the licensee provided the initial evaluations for a number of the missed comitments. The inspector reviewed the evaluations and noted that, based on the initial review,.17-items had no safety consequences. Further, the guidance for issuing a Problem Report,v: hen findings were-identified, was being considered for improvement.- Interviews revealed that the issuance of a problem report would ensure adequate evaluation, root cause determination, corrective actions to prevent recurrence, and a deportability revie . The inspector reviewed the documentation for the completion of selected items which had been identified by the licensee. The licensee's November 3, 1986, letter (ST-HL-AE-1796) to the NRC

. provided 'comitments. for the NRC regarding flooding and included

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the> provision for aniadditional source of demineralized water for makeup to.the Component Cooling Water (CCW) surge tank. The inspector reviewed procedures (1 POP 09-AN-02M3 and 2 POP 09-AN-02M3,

"CCW Compartment Low-Low Level") to verify that additional-l

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procedural guidance was provided. Operator interviews and document reviews revealed that the procedures were provided and that the actions required to provide emergency makeup to the CCW surge tank wereLaddressed in the procedure ~

l Letter ST-HL-AE-2033, dated April 8, 1987, provided additional 3 information to the NRC regarding the fire. protection features at i STP associated with the responses to fires, alarms, system l monitoring, and updating of the licensing documents. The l- comitments were verified to be addressed by the licensee in Procedure OPGP03-ZF-0012. " Fire Fighting," Revision 1; and i Procedure OPGP03-ZF-0018 " Fire Protection Operability '

Requirements," Revision 5; and FSAR, Section 9.5.1.

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-8-Letter ST-HL-AE-2265 to the NRC dated June 23. 1987, addressed the use of jumpers and lifted. leads during routine maintenance procedures and surveillance and testing activities. The letter specifically addressed the use of jumpers or lifted leads associated with the radieAion monitoring system and the revisions to the associated test procedures prior to full power licensing, such that ESF actuation signals were not blocked by lifting leads. The rereview of the letter by the licensee in 198.8-identified that the Procedure 1 PSP 1A-RA-1106, " Plant Operation Airborne Monitors Response Time Surveillance," had not.been revised as stated. The procedure was revised on April 25, 1988, to remove the steps that required the blocking of the ESF '

actuations associated with the RCB Purge Isolation Monitors

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-(A1RA-RT-8012 and CIRA-RT-8013), Spent Fuel Exhaust Monitors

. ( AIRA-RT-8035 and C1RA-RT-8036), and Control Room / Auxiliary

. Building Ventilation Monitors (A1RA-RT-8033 and CIRA-RT-8034).

The following procedures associated with each system were also reviewed by the inspector to verify that the system was initiated and checked, as appropriate:

OPSP14-RA-1113. " Spent Fuel Pool Exhaust Monitors Response Time Testing," Revision 0 (November 4, 1988); ,

1/2 PSP 14-RA-1109, " Control Room / Auxiliary Building Ventilation Monitors," Revision 0/0 (November 4, 1988); and 1/2 PSP 14-RA-1107, "RCB Purge Isolation Monitors," Revision 0/0 (November 4,1988).

E0P 1P0505-E0-ES02, Revision 4, and E0P 2 POP 05-E0-ES02, Revision 0, " Natural Circulation Cooldown," steps 5.1 and 12.1, addressed the maintenance of reactor vessel head subcooling using the reactor head vent path, until the residual heat removal system was placed into service. The inspector also noted that the entry point into E0P IP0P-E0-ES03 and E0P 2 POP-E0-ES03,

" Natural Circulation Cooldown With Steam Void in Vessel," was subsequent to the completion of v ms 1-13 of E0P 1/2 POP 05-EO-ES02,

" Natural Circulation Cooldown,' ircuctor head subcooling being maintained utilizing all control rod drive met.hanism fans or one reactor vessel head vent path to the pressurizer relief tank).

Interviews and document reviews revealed that Procedure IP-1.4Q,

" Interdepartmental Procedures Preparation and Review of Submittals to the Nuclear Regulatory Commissicn," Revision 2, was revised as a result of the failure te meet the licensee's l

commitments. However, the procedure was presently being

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considered for further revision to provide an independent i

verification of the completion of commitments to further enhance

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the program requirements, i

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-9- -i The review of Nuclear Group Policy, NGP-610. " Licensing Commitments," Pevision 3. revealed that the specific management approvals were required for the revision to or withdrawal of a commitment to the NR *

Interviews and document reviews revealed that the ongoing procedure enhancement program included the E0Ps. The implementation of the upgraded E0Ps was scheduled to be complete July 16, 199 The inspector had no further questions regarding this matter, with the exception of the completed evaluations of the 22 missed commitments and the corrective action to prevent recurrenc This deviation will remain open pending the review of the completed licsnsee evaluations and corrective actio .2 Unresolved Items (92701)

2. (Closed) Unresolved Item (498/8852-01; 499/8252-01) - Inspection Program: The unresolved item concerned an apparent programmatic weakness in the licensee's quality program requirements for establishing minimum inspection activities associated with certain routine safety-related work activitie The inspector reviewed selected procedures associated with the control and implementation of safety-related maintenance activities, including:

OPGP03-ZA-0002, " Plant Procedures," Revision 16; OPGP03-ZA-0039,

" Plant Procedures Writers Guide," Revision 8; OPGP03-ZM-0003,

" Maintenance Work Request Program," Revision 6; OPMP01-ZA-0004,

" Maintenance Procedures," Revisicn 6; OPMP02-ZG-0005, " Work Planning," Revision 5; and QP 2.0, " Inspection Activities,"

Revision 4 Procedure OPMP01-IA-0004, step 2.2, addressed the establishment of quality hold points by the maintenance / performance group; however, Addendum 6 of OPGP03-ZA-0002, " Plant Procedures," specifically called out that QIPs were for nonroutine activities and "were not necessary or may not be appropriate for routine activities." Procedure OPGP03-ZM-0003, step 4.10, specified that Operations Quality control review the maintenance work request / package to verify that QIPs were specified; however, Procedure QP 2.0, step 6.5.3, noted that inspection activities should be applied to nonroutine maintenance activities (other than routine, preventive maintenance, calibration, and testing).

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,d > ,Ihterviewsrevealedthattheinspectionprogrambeingimplemented,

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lregarding ' safety-related activities at STP, was considered by the f ,

licensee to be acceptable.

4 ;;> The inspector identified no specific equipment failures due to a lack h of: inspection / verification during' normal plant operations and testin The inspector had no further questions regarding this matte l' , .This unresolved item is close . (Closed)UnresolvedItem-(498/8852-02;'499/8252-02)- Emergency-Operating Procedure-(EOP) Upgrade: The inspectors reviewed the licensee procedure enhancement program, which included the enhancement of the E0Ps. Document review and interviews' revealed that the Lprocedure enhancement program was provided to resolve the numerous concerns identified regarding the quality of the E0P The E0P enhancement program was being accomplished in accordance with a revised E0P writers _ guide and included a ruulti-step process for-development of the new E0Ps. The process included in-plant walkdowns (92 of 98 EOPs-complete), E0P revision process (33 of 49,E0Ps-

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complete), independent technical /multidiscipline reviews:(11 of 49 E0Ps complete), interdepartmental reviews (human factors), in-plant validations, simulator evaluations / revisions, editorial reviews, PORC

reviews, and personnel training (all licensed personnel and-selected others).~ The schedule for completion of the E0P upgrade process was July 16. 1990.. The 'icensee stated that the E0P enhancement program was on schedul The concerns expressed by the NRC in this unresolved item were

. included in the E0P enhancement program. This item is also considered to be a part of Violation 498/8868-02, " Inadequate Emergency Operating

~ Procedures."

The inspector had no further questions concerning this ite This u:, resolved item is considered to be close .3 Open Items (92701)

l L ;2. (Closed) Open Item (498/8805-02; 498/8805-02) - E0P Writer's Guide The open item concerned the lack of guidance in

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and Commitments:

the E0P writers guide to ensure that applicable commitments were

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The inspector reviewed Procedure OPOP01-ZA-0006, " Emergency Procedure Writer's Guide and Verification," and OPOP01-ZA-0016. " Emergency Procedure Writers Guide." The procedures referenced the Licensee Comitment Tracking System (LCTS) in step 20.6, NUREG-0899 in step 21.2.of Procedure ZA-0006, and specific commitments in Section 16 t of Procedure ZA-0016. The source documents section also addressed the Westinghouse Owners Group (WOG) guidelines in step 20.1 of l- Procedure ZA-0006, and in Section 16 Procedure ZA-0016, and specific NRC commitments in step 21.4 of Procedure.ZA-0006, and in Section 16, Procedure ZA-001 This item is close .3.2 (Closed) Open Item (498/8805-03; 499/8805-03) - Commitments into Procedures: The open item concerned the adequacy of the LCTS and the f review of letters from HL8P to NRC dated June 1986 to present, to ensure implementatio The inspector's review of this item was performed as part of the followup of Deviation 8805-001 (paragraph 2.1.3). The inspector's review included the.LCTS guidance document and computer printouts, the revised nuclear policy NGP-610, ard the revised interdepartmental procedure,IP-1.4 The-inspector found the licensee's programs to be adequate with regard.to the specific interests noted in the open ite This item is closed.

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2.3.3 (Closed) Open Item (498/8852-03; 499/8852-03) - Human Factors Review: The open item concerned the failure to provide a rigorous human factors review of the E0Ps to ensure that the E0Ps were clear, organized, and consistent with the writers guid The licensee had established and implemented the procedures enhancement program, including the E0Ps. The E0P enhancement program was being accomplished in accordance with the revised E0P writer's guide and included a multi-step process for development of the new E0Ps. Interviews revealed that the program included a human factors review as part of the interdepartmental review (see paragraph 2.2.2).

TMs item is part of Violation 498/8868-02, and is close .3.4 (Closed) Open Item (498/8852-04; 499/8852-04) - Three Commitments Regarding the Procedures Generation Package (PGP): The open item ccncerned the failure of the licensee to include commitments provided to the NRC in letter ST-HL-AE-1848 associated with the procedures generation package.

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The inspector reviewed Procedures OPOP01-ZA-0006, "EOP Writers Guide and Verification," Revision 4, and OPOP11-ZA-0016 "EOP Writers-Guide," Revision 0, which included the specific references to NRC I commitment letters - Sections 21 and 16 referenced letters ST-HL-AE-1848 and ST-HL-AI-7151, respectively.-

The inspector found the licensee's programs to be adequate with regard to the' specific interests noted in the open ite This concern is a part of Violation 498/8868-002," Inadequate Emergency Operating-Procedures," and is close . (Closed) Open It'em (498/8868-03; 499/8868-03) - Verification and Validation of E0Ps: The open item concerned a number of weaknesses associated. with the E0P verification and validation proces The inspectors reviewed the licensee procedure enhancement program, which included the enhancement of the E0Ps. Document review and interviews revealed that the procedure enhancement program was provided to resolve the numerous concerns identified regarding the quality of the E0P The E0P enhancement program was being accomplished in accordance with a revised E0P writers guide and included a multi-step process for development of'the new E0Ps. The process included in-plant E0P walkdowns (92 of 98 E0Ps complete), E0P revision process (33 of 49 E0Ps complete), independent technical multidiscipline reviews (11 of 49 E0Ps complete), interdepartmental reviews, in-plant validations, simulator evaluations / revisions, editorial reviews, PORC reviews, and personnel training (all licensed personnel and selected others). The schedule for completion of the E0P upgrade process was July 16, 1990. The licensee stated that the E0P enhancement program

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was on schedule (see paragraph 2.2.2).

The concerns expressed by the NRC regarding this open item were included in the E0P enhancement program. This item is a part of Violation 498/8868-02, " Inadequate Emergency Operating Procedures."

The inspector had no further questions concerning this item, and it is close ' 2. (Closed) Open Item (498/8868-04; 499/8868-04) - Reactor Containment Entry to Complete Immediate Action in E0P: The open item concerned Imediate Action step 3.2 of 1/2 POP 05-E0-EC00, which required a reactor containment entry to complete an immediate action ste .

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i The inspector reviewed plant procedures for each unit, IPOP05-E0-EC00, Revision 6, and 2 POP 05-E0-EC00, Revision 1, " Loss of All AC Power." to verify that the NRC concern had been addressed and the action step had  !

been changed. The step had been deleted and the present procedures, step 3.2.2 required closure of the outside containment letdown isolation valve (1-CV-MOV-0024. Unit 1, and 2-CV-MOV-0024, Unit 2) by the reactor plant operator locally. The inspector also noted similar steps associated with 1-CV-MOV-0079 and 2-CV-M0V-0079, " Excess Letdown -

Flow and Seal Return," outside containment isolation valve This.open item is close .3.7 (0 pen) Open Item (498/8868-05; 499/8868-05) - Inadequate Emergency Lighting:' The open item concerned the lack of emergency lighting to support E0P action l The. inspector toured selected areas of the plant (auxiliary shutdown {

panels and electrical switchgear rooms) and noted the availability of emergency operating kits, containing procedures, sound-powered phone headsets, and keys.. A ladder was noted in one area to provide access to equipment. . Discussions and observations revealed that the operations personnel had small flashlights in their possession, an )

interim measure. pending the completion of the E0P enhancement program i and the necessary modifications to the emergency lighting. The E0P i in-plant walkdowns performed by the licensee included the verification l that emergency lighting was adequate to support local E0P action The walkdowns were scheduled to'be completed in the near future (end of July 1989). Interviews revealed that the walkdowns were nearing  ;

completion and included the sirnulated performance of E0P steps in the field without use of normal lights or flashlights. The lighting deficiencies identified were documented and a subject of review with

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the engineering group to determine the corrective actions. The following areas were reviewed by the inspector regarding the  ;

licensee's activities associated with this item:

During in-plant tours and interviews by the inspector, it was I noted that most of the operations personnel carried metal flashlights. The inspector noted that some of the E0P actions were asso'ciated with electrical equipment and the metal flashlights could represent a potential safety hazard. This concern was presented to the licensee for consideratio * -The administrative controls, requiring the possession of flashlights at all times by all operations personnel, were noted to be included on the station night orders, dated November 4 and 7, 1988, for Units 1 and 2, respectively. The requirement was again entered in the night orders on February 2, 1989, for l both units. Other administrative controls, such as routine j surveillance or shift turnover check sheets, were not established '

by the license ,

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- Routine inventory of the local emergency operating procedure kits and equipmert (procedures,. seals, ladders, keys, phones, relay sticks, etc.) has not been implemented. An inspection of

.the local kits revealed a number of inadequate seals and a l

broken has These matters were brought to the attention of the licensee for

, consideration. The licensee repaired the hasp and placed locks on the local kits. The key to the lock on the local i kits was verified to be included.on the operator's key rin {

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During the inspection, the licensee provided the initial results j of the detailed walkdown of each E0P to determine if the emergency lighting was adequate to allow performance of the required actions. The walkdown of Unit I and Unit 2 E0Ps was completed on June 21, 1989. Document review and interviews revealed that the lighting discrepancies were to be discussed 1 with the engineering group to develop a corrective action plan.-

l This item will remain open pending the completion of.the corrective action plan and subsequent review of the matter by the NR . (0 pen) Open Item (498/8868-06; 499/8868406) - Environmental Conditions Associated with E0P and Off-Normal Procedure Actions:

The open item concerned the lack of a study to determine the expected postaccident environmental conditions (radiation and temperature) in the plant areas where operator actions were required as specified in NUREG-057 During the inspection, the licensee provided the preliminary actions taken to' determine the acceptability of the environment in the areas where E0P actions were to be implemented. Problem Report SPR 88-0435, was issued to evaluate and disposition the limits on operator actions as a result of high radiatio .

This item will remain open pending the NRC review of the study completed by the licensee and assessment of the corrective actions taken or planne No violations or deviations were identified during the review of this .

program are i 3.0 Procedures Review (42700)  ;

The inspectors reviewed and evaluated selected plant procedures to verify that the. procedures and procedure changes for safety-related activities were in conformance with the Technical Specifications and administrative l

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controls,:were technically adsquate, and.were consistent between Units 1

.and Procedures and administrative controls in the following areas were selected for review:

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' General plant operating procedures c'

Safety-related system startup, operation, and shutdown proccdures

• ' Off-normal / alarm procedures

Emergency operating procedures

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Maintenance procedures

Temporary procedures 3.1 Administrative Procedures l

< The inspectors. reviewed administrative procedures. The procedures that

< were reviewed and for which no concerns were identified are listed in the Attachment. The inspectors identified concerns and provided. comments regarding several,of the procedures reviewed. The procedures and inspector's

. concerns / comments are discussed belo *

. Paragraph 11.3.4 of OPGP03-ZA-0002, " Plant Procedures," Revision 3,

' required that, "The Plant Manager SHALL review all Field Change L

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packages and signify approval . . . ." Copies of'FCRs could be placed in the controlled copies of the active procedures prior to receiving the' approval signature of the Plant Manager (Section C of the FCR left blank).. The FCRs were to exist in this state (unapproved) for.only 14 days. After the elapse of 14 days, the person using the procedure could only assume;the FCR was, in fact, approved by the Plant Manage a '

The inspectors.found that the completed (approved) FCR was routed to the records management group for ratention, and that the operations

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personnel did not. verify nor were they notified that the FCR was fully approved (Section C of the FCR completed). ~A number of the approved FCRs attached to current procedures were in excess of 14 days ol These procedures were available for routine use based upon the assumption made by the user that the attached FCR had been reviewed and approved as required. No FCRs were identified by the inspectors

' . which had not been processed appropriatel Section A of the FCR (Description Section) did not require enough information(e.g.,reasonthepresentprocedurewasnotacceptable and the steps affected) to ensure adequate and efficient review and approval of the chang * Procedure OPEP03-ZA-0039, " Plant: Procedures Writer's Guide,"

Revision 8, included FCR 89-1508, issued against Revision 9 of the l procedure, when the FCR should have been. issued against' Revision FCR 88-1270 was issued against Revision 8 when it should have been

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issued against Revision 7, prompting the later FCR 89-1508. A number of licensee personnel signed the review and approval of these FCRs and i

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revisions; yet they had not noted the discrepancies. This specific example was not of itself significant; but it was of concern that the oversights occurred in the procedure that encouraged exactness and attention to detail in procedure writing. This matter was discussed with the licensee for consideratio Procedure OPOP01-ZA-0007, " Plant Operations Procedure Writers Guide,"

Revision 3 (April 21,1989), was reviewed by the inspector. No significant problems were found and the procedure appeared to be a well written guide for procedure writers. However, a review of procedure References 10.1 (0PGP03-ZA-0002) and 10.2 (0PGP03-ZA-0039)

indicated that procedural and control deficiencies should receive more attention to detail (see paragraphs above).

Procedure OPG03-ZA-0031, " Temporary Hose Control," Revision 0 (July 14, 1988), was reviewed and it was found that it had not been adequately implemented. A temporary hose was attached to N1SS-AE-4829 with no hose ID Tag. attached as required by step 4.4 of the procedur Another temporary hose was attached to NISS-AE-4832 that did have an ID Tag. Additionally, the installation date was marked " unknown" and the expiration date was marked " indefinite," which implied that this was not intended to be temporary by the per on installing th? hos Also, it appeared that the exceptions listed in paragraph 1.2 of the procedure need to be reevaluated by management a ensure the iatent of the procedure was being complied with in other approved procedure No violations or deviations were idertified during the review of these procedure .2 General Plant Operating Procedures The inspectom reviewed selected general plant operating procedures. Those procedures for which no concerns were identified are listed in the Attachmen Procedures 1 POP 03-ZG-0001, " Plant Heatup," Revision 11, and 2P0P03-ZG-0001, " Plant Heatup," Revision 2, were generally goo However, the following comments were provided to the licensee for consideration:

Step 4.4 should be clarified by indicating the use of the spray valves in manual control at the stated plant condition Step 6.4.5 should be strengthened by referencing the additional pressurizer level channels in addition to the cold calibrated wide range level channel in order to provide additional assurance that the pressurizer liquid level was not drained below the heaters.

l Additionally, the total reactor coolant volume change was not calculated nor specifically required to be monitored during the draining evolutio ;  : y

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'3.3: System Ope'ating r Procedures e g LThe inspector reviewed selected system operating procedures. The a j inspector's concerns and comments are documented belo ^

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3. POP 02-RH-0001, " Residual Heat Removal System Operation," Revision 21 (March 7,1989) ,

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l References 2.4.1 and 2.4.5 associated with precautions 4.5.and' .were written as if they were references when actually they were Action Plan' Items used as esferences.. Procedure OPOP01-ZA-0007

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provided a specific method for referencing and' branching and did not (provide guidance'for inclefing Action Plan Items'in the operating procedure ' Steps 5.14, 7.5, and 11.4 did not comply with the provisions ofL

.0 POP 01-ZA-0007. paragraph'8.0 (Writer's Guide).

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, Technical. Specification 3.4.1.3 requires that the valves be locked o pinned in position to limit flow to 125 gpm in the RHR loop "- Valves CV0198 A, B, and C were not addressed in the procedures text or systen lineup _ check sheets, nor were they addressed in 2P0P02-CV-0004 text'or system lineup sheets. The Unit 2. supervisor demonstrated during an interview that he was able to show how this valve position

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was verified ~ during a plant cooldown-in 2 POP 03-ZG-0007 and in the control ~ room and RP0 logs where this valve status'was checked each 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> In steps 7.5 and 12.0, a series of operations required temporary eauipment. These steps were approved.in this procedure without the amplifying guidance provided in OPG03-70-0031 or OPG03-20-00 Requirements of OPG03-ZO-0031 were'not applicable in other approved procedures according to paragraph:1.2.a and in paragraph 1.2 of OPG03-Z0-0003. The intent .to provide radiological, environmental, and personnel protection guidance in these two procedures could be overlooked or avoided because the steps in 2 POP 02-FW-0001 and 2 POP 02-RH-001 did not include sufficient direction for these operation .

The term PROCEED used in step 11.4 was not an approved branching method according to OPOP01-ZA-0007, " Plant Operations Procedures Writer's Guide," paragraph . POP 02-FW-0001, " Main Feedwater," Revision 1 (November 12,1988).

S (FCRs 89-1141, 89-1018, 89-0457, 89-0433, and 88-2402)

Step 5.7, amended by FCR 89-1441, used the term J0G. J0G was a non-descriptive action verb NOT on the approved list in Addendum 2 of OPOP01-ZA-0007, " Plant Operations Procedure Writer's Guide." The

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original wording appeared to be more ' descriptive.~than that provided by-the change. The reason fo- the change asl stated in FCR 89-1441 was to

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" correct errors." This section should'have been used to more i

. adequately define the exact reason for making a field change. .Itl

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appeared that this FCR would also apply to Unit 11; however, the Unit 1

. procedure was not changed. More than 14-; days had passed and n similar:FCR for Unit I had been issued even though the same steps existed'in IPOP02-FW-000 'The action specified in step 5.8 should be. performed prior to; y'

step 5.7; otherwise, step 5.7 may be unnecessary or too lat ,

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In step 5.13,. VENT was underlined and capitalized,' indicating a logic-term and not an action. verb per the guidanc '

Step 6.4.4 did not adequately define the term " properly warmed."~

The changes covered by.FCR 89-1018 started on page 11A, step 8. .However, it was inserted in front of step 7.3.10 and_ step This could contribute to a procedural erro Step 8.2.2 did riot adequately. define the expected final position o 'handswitches HS-0365, -0366; -0368 and -037 Step 8.2.6 contained an unapproved action verb - J0 Step' 8.3.1.1 required the installation of_ a temporary hose for venting purposes. The inspector conducted a walkdown of this step with a Unit 2 RPO. The RP0 reviewed the procedure and referred to OPG03-Z0-0031,

" Temporary Hose Control." .He pointed out:the vents, the hose'

adapters, and the hose; and noted that these vents could not be reached.without-a very tall ladder.. The ladder was'available in the-

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turbinegenerator-building (TGB).

The inspector interviewed the Unit' 2 HP supervisor concerning contamination surveys'in the TGB.and specifically asked about the contamination of temporary hose internals. The HP supervisor stated that the TGB was routinely surveyed and hoses would be surveyed if

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suspect. However, the hoses were not routinely monitored. This

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-approach to contamination control may need to be reevaluated considering a steam generator tube leak or ruptur No violations or deviations were identified during the review of these procedures.

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3.4 Off-Normal and Annunciator Procedures The inspectors reviewed the following procedures to determine adequacy

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based on the Technical Specification 6.8, Regulatory Guide 1.33, and 1.35 and the STP FSAR (Sections 13.5 and 17.2). The procedures that were

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reviewed and for which no concerns were identified are listed in the Attachment. The inspectors identified concerns and provided comments

, regarding several.of the procedures reviewed.- The procedure and inspector's concerns / comments'are discussed belo .o 3. OPOP04-RH-0001, " Loss of Residual. Heat Removal," Revision 1

.(December. 16,1988) .

Step 5.2.2.2 required the operator to open RWST.to charging pump ,

. suction-isolation' valves with no reference to closing the VCT outlet valves. . This was inconsistent with1similar operations required in steps'5.2 of OPOP04-CV-0003, Revision 0, dated Decueber 16, 198 This comment was made previously in NRC Inspection Report 50-498/88-54; 50-499/88-54, concerning,2P0P04-RH-0001 and 2 POP 04-CV-0003. Both of these procedures have been revised without providing consistency within the procedure '

.It"sppeared that step 5.6.4 should precede step 5. L

.The wording of steps 5.8 and 5.9 were not in accordance with OPOP01-ZA-007, paragraph 8.0 (Writer's. Guide).

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3. '.0P0P04-FW-0001, " Loss of Feedwater Flow or Controi," Revision'0 (December 16,1988)

Step 5.6 did not provide a tolerance band for pressure control, nor

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provide direction if pressure was not at 2235 psig, or if a level

. deviation alarm was presen The procedure did not address the failure of an instrument channe During the inspection, the licensee proviceo the inspector with a revision to the procedure (FCR 1726) which addressed the failure of a level or pressure channel, including the immediate and supplementary operator actions and the necessary corrective actions per TS 3. The immediate actions taken in this specific instance appeared to be acceptable.

p 3. OPOP04-CV-0003, " Emergency Boration," Revision 0 (December 16,1988)

Step 5.1.6 was a "G0 T0" step that appeared only to bypass step . OPOPO4-TM-0001, " Turbine Load Re,'ection," Revision 0 I

The procedure addressed the actual turbine load rejection, but it did not address the failure of the selected turbine impluse pressure channel and a malfunction of the automatic reactivity control system (see paragraph 3.4.9).

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3.4.5 OPOP04-RS-0002, " Malfunction of Rod Control," Revision 0 The procedure addressed the malfunction of the rod control system hardware control cabinets, but it did not address a malfunction of the automatic reactivity control system (see paragraph 3.4.9).

3.4.6 OPOP04-RP-0001, Revision 0 (December 16, 1988), " Loss of Automatic Pressurizer Pressure Control" (FCR 89-1613 dated June 14,1989)

The inspector reviewed FCR 89-1613 to ensure that it referenced the appropriate Technical Specifications (TS). The FCR, which added the TS references to the procedure, appeared'to be acceptabl The review disclosed the following two specific areas of concern which were discussed with the licensee for evaluation and resolution:

The stated procedure objective was to provide guidelines for maintaining reactor coolant system pressure during a loss of automatic pressurizer pressure contro The symptoms (2.0) included instrument failure, pressure increasing or decreasing, and pressurizer relief valve leakag These symptoms appeared to apply only if the pressure control was. lost. The control system utilized only two of four available channels. If the failed channel had not been selected for control, the procedure did not specifically apply. The procedure did, however, address the selection of two pressure channels (other than the failed' channel) and the requirements to place the failed pressure channel bistables in the tripped condition per the T The procedure did not address the loss of pressure control or a pressure channel when in the low temperature / low pressure operating' conditions during normal heatup and cooldown evolution The failure to provide an adequate procedure addressing the failure of the reactor protection ch nnel (pressure) during normal operating conditions and durn., low temperature / low pressure operations is an apparent violation of TS 6.8.1 which i -requires that procedures are to be established for safety-related L activities (498/8915-01; 499/8915-01).

During the inspection, the licensee provided the inspector with a revision to the off-normal procedure (0P0P04-RP-0001, Revision 0, FCR89-1725) which expanded the objective of the procedure to address the low pressure operating condition and instrument failures. The immediate actions taken in this specific instance appeared to be acceptable.-

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3.4.7 OPOP04-RP-0002, " Loss of Automatic Pressurizer Level Control "

Revision 0 (December 16,1988)

The review of the procedure identified an area of concern which was discussed with the licensee for further evaluation and resolutio Specifically, the stated procedure objective was to ptovide guidelines for maintaining reactor coolant system inventory during a loss of automatic pressurizer level contro The symptoms (2.0) of the procedure included pressurizer level increas: 1 or decreasing, instrument failure, and letdown isolatio These symptoms. appeared to apply only if the level control was los The control system utilized any two of three selected level channel If the failed channel was not selected at the time of the failure, the procedure did not specifically apply. The procedure did, however address the selection of two level channels (other than'the failed channel) and the requirements to place the failed level channel bistables in the tripped condition per the T The' concurrent failure of two of four pressurizer level channels o May 6 and 12, 1989,- respectively, on Unit 2 as reported in LER 89-015, dated June 12, 1989, demonstrated this type of channel failure. These events, even though not causing a transient / pertubation on the reactor coolant system, emphasized the need for detailed written procedures addressing the loss of a protective system channel (reference -

Item 6.k. of Appendix A to RG 1.33).

The licensee's failure to provide an adequate procedure addressing the failure of a reactor protection channel (pressurizer level) is another example of the violation of TS 6.8.1 cited in paragraph 3. abov During the inspection, the licensee provided the inspector with a revision to the off-normal procedure (OPOP04-RP-0002, Revision 2, FCR89-1724) which expanded the objective of the procedure to encompass instrument failures. The immediate actions taken in this specific instance appeared to be acceptabl .4.8 Loss of Reactor Protection Channel (Temperature)

The review of the licensee's off-ncrmal procedures revealed that a the loss of a temperature charnel [RCS specific hot procedure leg (Th) or RCSaddressing cold leg (Tc) resistance temperature detector (RTD)] was not provided. The transient resulting from the expected loss of an RCS temperature channel could affect numerous protection and control systems requiring specific, and in certain cases extensive, operator actions regarding the affected pro;ection and control system .. _ _ _

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The licensee's failure to establish written procedures' covering this activity is another example of the violation of TS 6.8.1 cited in paragraph 3.4.6 abov .4.9 The specific and general concerns regarding the failure to establish written off-normal procedures were discussed with the licensee. The discussions. revealed that a number of off-normal conditions had been identified by the licensee and procedures were being written or considered at the time of the inspection. The conditions being evaluated included:

Failure of RCS Loop Flow Transmitter

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Failure of' Turbine Impulse Pressure Transmitter

Loss of Instrument Power Loss of Spent Fuel Pool Level or Cooling The inspector reviewed an internal memorandum dated June 29, 1989, addressing'the review of the eff-normal procedures and' annunciator procedures associated with TS instrumentation. The review by the licensee, and subsequent discussions with the inspector, revealed the need to upgrade the annunciator and off-normal procedures to assure that the expected transient was fully addresse The STP-FSAR, Section.13.5.2, included.the statements that the plant operating procedures that will be prepared initially included off-normal operating procedures which will provide the necessary instructions for restoring an operating variable to its normal controlled valu The STP FSAR also noted that the minimum list of off-normal operating procedures to be prepared initially included:

Plant Electrical Systems Off-Normal The inspector noted that the electrical system at STP included a number of electrical power systems (e.g., 13.8 kv, 4.16 kv, 480 V, and 120 V AC; and 250 V and 125 Y DC). As stated above, the licensee had not provided an off-normal procedure for the loss of instrument power. This area should be evaluated by the licensee to determine if other areas have been overlooke * Malfunction of Rod Control System As stated above, the procedure provided addressed only the control rod drive system hardware and not the irrpact of the failure on the reactivity control syste * Turbine Load Rejection

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The off-normal procedure addressed an actual turbine load decrease. As noted above, the licensee had not provided a procedure for the failure of the turbine impulse pressure channel considering,the impact of the failure on the automatic reactivity n control system or the main turbine bypass (steam dump) syste .4.10 The inspector reviewed a number of annunciator procedures to assess the adequacy of the procedures and to determine if the procedures were inclusive of the expected perturbations or abnormal conditions selected for revie *

1 POP 09-AN-05M2, " Turbine Impulse Pressure Rod Withdrawal Blocked," Revision 3 The annunciator procedure assumed that the pressure channel failed downscale and addressed the automatic control rod withdrawal block when the turbine power (impulse pressure) was less than 15 percent of full power. The procedure was to be changed to reflect the failure of the turbine impulse pressure instrumentation and for the operator to select the turbine impulse pressure channel which had not faile i

1/2P0P09-AN-05M2, " Reactor Coolant Pressure High Arm COPMS."

Revision 3/1 The procedures for windows B-6 (Train A) and B-7 (Traf a B) did not address a failed instrument channe /2 POP 09-AN-05M2, " Temperature Average /Auctioneered Temperature Average Deviation High or Low," (plus or minus 2*F)"

The procedure did not address a failed instrument channe /2 POP 09-AN-05M2, " Temperature Average Lo-Lo Normal Steam Dump Blocked Alert," Revision 3/1 This procedure did address a failed average temperature channel (less than 565*F).

1/2 POP 09-AN-05M2, "Auctioneered Average RCS Temperature High,"

(3 F or more above the normal 100 percent value)

The-procedure did not address a failed temperature instrument channe IPOP09-AN-05M2, " Temperature Reference /Auctioneered Temperature Average Deviation,"' Revision 3

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The annunciator procedure addressed a reactor coolant system (RCS) temperature transient of 3 F difference between the average temperature and the reference temperature and was to be changed to address an instrument failure, including the turbine impulse pressure instrument. The procedure did not specifically address.the malfunction of the automatic rod control system as a result of other failures; however, the procedure required the operator to take manual control of the control, rods and control the RCS average temperature within limits and take appropriate actions per T *

1/2P0P09-AN-05M2, " Reactor Pretrip (108%)," Revision 3/1 The procedures for windows A-5 and A-6 did not address a failed instrument channel.;

1/2 POP 09-AN-05M2, " Reactor Temperature Low Arm COPMS,"

Revision 3/1 The procedure did not address'a failed instrument channe With the one exception (1/2 POP 09-AN-05M2, " Temperature Average /Lo-Lo-Normal Steam Dump Blocked Alert"), the procedures reviewed did not address a failed instrument channe The' inspector concluded that, in general, the licensee prepared the annunciator and off-normal procedures considering operator actions in response to plant transients with control system malfunctions and had not written the procedures to diagnose and respond to plant perturbations caused by protection / control system malfunction Interviews revealed that system instrument failures were included routinely in' plant simulator training for the licensed personne ,

The inspector interviewed the on-shift control room operators and conducted a simulated loss of pressurizer pressure control / protection channel to assess the operator actions associated with the malfunction. The actions taken by the operator were acceptable, demonstrating a good understanding of the pressurizer pressure instrumentation and control system. However, the evaluation performed

.by the inspector was during normal operating conditions (little or no stress on the operator) and a less knowledgeable operator may not have performed as well; emphasizing the need for comprehensive, well-written procedures which address the expected / predicted plant transients and extensive training to these procedure The failure to establish written procedures addressing the malfunction of the automatic reactivity control system is another example of the violation of TS 6.8.1 cited in paragraph 3.4.6 above.

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3~ 5 Emergency Operating Procedures

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The inspectors reviewed the selected emergency operating procedures listed in the Attachmen No violations or deviations were identified during the review of these procedure .6 Mechanical Maintenance Procedures The inspectors reviewed the maintenance procedure listed in the Attachmen No violations or deviations were identified during the review of this procedure.

3.7- Electrical Maintenance Procedures The inspectors reviewed the selected electrical maintenance' procedures listed in the Attachmen No violations or deviations were identified during the review of these procedure . I&C Maintenance Procedures The inspectors, reviewed the I&C procedures listed in the Attachmen No violations or deviations were identified during the review of these procedure .9 Temporary Procedures The inspectors reviewed the selected temporary procedures listed in the Attachmen No violations or deviations were identified during the review of these procedure .0 Technical Specification (TS) Changes The inspector reviewed selected portions of the following amendments to the facility license to ensure that.the items were implemented:

Amendment No. 6, dated March 28, 1989, was associated with TS 3/4.7.8, " Fuel Handling Building Exhaust Air System." The inspector reviewed Procedure OPSP11-ZH-0007, "EAB and HVAC Filter Heater Performance Test," Revision 2; the data packages associated with Unit 1 FHB Exhaust Filter Trains A and B, dated May 2,

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- :1989; and 'th'e ~ data packages' associated with Unit' 2 FHB Exhaust Filter 1 Trains A and B,. dated April 26, 1989. _The tests. appeared to'be acceptable and was~ performed within the 6-week time frame specified in the 'TS change.:

F *- Amendment'No. 7,: dated March 28, 1989, concerned TS 3.3.3.7, " Control Room Chemical Detection System," and TS 4.7.7.e, " Controls Room Makeu and Cleanup: Filtration System." -TS 3.3.3.7. specifies the"setpoints for: ' a) vinyl acetate 'and b). anhydrous ammonia / ammonium hydroxid TS 4.7.7.'e.5 specifies that the control room' system automatically switches into a recirculation node of operation within'5 seconds of

exceeding the1specified limit a The inspector 1 reviewed Procedure OPSP11-HE-0002,'" Control Room' Emergency Air Cleanup System Functional-Test," Revision:4; the completed data

. package. associated with Unit I controlLroom system, dated January 11

.and 18,-1989; and the completed data. packages associated with Unit 2 control room system, dated December,12, 1988. The three trains in both

' control room. systems isolated in'less than 5 second 'The inspector: reviewed Procedure 1 PSP 02-HE-9325 " Control Room Air Inlet

' Toxic Gas Analyzer'ACOT (X-9325)," Revision 2; Procedure 2 PSP 02-HE-0325,

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" Control.RoomAir.InletToxicGasAnalyzerACOT'(X-9325),". Revision 1;'and

, 1the: associated data packages,-dated June 2, 1989, and. June 2 and 10, 1989,

.respectively. ;The.. inspector also observed the units in the field, reviewed the data. recorded"and checked by the operations group, and inspected-the annunciator windows in.the control room. The implementation of_the setpoint.and procedure changes, required by the licensee amendment Nos. 6

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and 7, appeared to'be adequat E ,

No violations:or deviations were identified during the review of this *

program are T4.1 Ouality Assurance Audit

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The' inspector reviewed the licensee's Quality Assurance audit performed by the nuclear assurance group in the area of instructions and procedures (Nuclear Assurance Audit 89-02 (D-6)). The audit was conducted during the

. period of January 16 through February 3,1989. The purpose and scope o '

the audit was to verify that instructions and procedures used to perform quality / safety-related functions were properly developed, reviewed,

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approved, and revised as required by the Technical Specifications,'FSAR, j >0perational QA Program, and administrative procedures,

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n Twelve potential deficiencies and two concerns were identified during the

'i - performance of the audit. Five deficiencies were subsequently issued because seven of the findings were corrected durb c the audit. The inspector..found that three of the five deficiencies had been close '!

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The inspector found that the audit checklist includet .: verification that written procedures have been established covering the applicable procedures recommended in Appendix A of Reg. Guide 1.33, Rev 2. Feb. 197 The audit checklist coments stated-that, " Procedure OPGP03-ZA-0001-describes.all type procedures contained in-the Plant Manual. The list of procedures adequately addresses all procedures recomended in RG 1.33."

The review of Procedure OPGP03-ZA-0001, " Plant Manual Description,"

Revision 9. revealed that the procedure described the Plant Manual organization and responsibility for procedures and policies. The administrative procedure addressed the categories of procedures; however, the procedure did not address the specific procedure requirements. This item was discussed with the licensee for consideration. It was noted by the inspector that a previous NRC violation (498/8868-07) questioning the adequacy of audits associated with the emergency operating procedures, in-that' deficiencies identified by the NRC had not been previously identified by. quality assuranc It appeared that the root cause of the previously identified finding may be similar to that which led to the concerns in the procedures audit (89-02). In the response to the NRC violation, dated February 14, 1989, the licensee committed to an enhancement of the audit program throughout 1989 to strengthen the program. The similarity of the two. findings (inadequate audits to identify deficiencies) was discussed with licensee representatives.. The licensee noted that the scope and the depth of audit 89-02 was considered adequate based on the licensee interpretation and understanding of the program requirement '

Procedure Category OPOP01-ZA (Operations) did not contain a specific listing of procedures (similar to the FSAR) needed at STP in order to meet the license requirements. The off-normal procedures had been developed over a period of time, initially from the FSAR, Chapter 13.5. It was not apparent to the inspector that the content of Audit 89-02 was adequate to identify the lack of coverage of expected plant transients in written procedures as required by the Technical: Specification, Appendix A to Regulation Guide 1.33, and to the FSAR. This overall program weakness needs to be further reviewed by the license I No violations or deviations were identified during the review of this program are .0 Exit Interview <

The inspectors met with the licensee representatives (denoted in paragraph 1.0) on June 16 and 30, 1989. The inspectors sumarized the purpose, scope, and findings of the inspection. The licensee acknowledged the coments and did not identify any proprietary informatio .

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p ATTACHMENT

'0PGP03-2A-0001, " Plant Manual Description," Revision 9 OPGP03-ZM-0003, " Maintenance Work Request Program," Revision 20

'OPMP01-ZA-0004, " Maintenance Procedures." Revision 6 OPMP02-ZG-0005,l" Work Planning," Revision 0

.DPOP01-ZA-0006, " Emergency Procedure Writer's Guide and Verification,"

. Revision 4 OPOP01-ZA-0016, " Emergency Operating Procedure Writer's Guide," Revision 0 (March 15, 1989) (FCR 89-0958, March 27, 1989)

< IP-1.4Q, Revision 3 " Interdepartmental Procedure Preparation and Review" 0PMP02-ZG-0004, " Fastener Torquing and Detensioning," Revision 1 (General)

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OPOP03-ZG-0004; " Reactor Startup," Revision 1

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IP0P03.ZG-0005, " Power Operations," Revision 4 2 POP 03-ZG-0005, " Power: Operations," Revision 0

<1P0P03-ZG-0007. " Plant.Cooldown," Revision 7 o

2 POP 03-ZG-0007, " Plant Cooldown," Revision 2

s OPOP04-NI-0001, " Source Range Nuclear Instruments," Revision 0 (December '16, 1988 Oh0P04-NI-0003, Revision 0(December 16, 1988), " Power Range Nuclear

' Instruments" 1/2 POP 09-AN02M3, " Component Cooling Water Compartment Low-Low Level,"

Revision 1/0 1 POP 05-E0-EC00, Revision 6 (January 15, 1989), and 2P0P05-E0-EC00, Revision'1-(February 3, 1989), " Loss of All-AC Power" 1 POP 05-E0-ES02, Revision 4 (October 10, 1988), and 2 POP 05-E0-ES02, Revision 0

.(November 6, 1988), " Natural Circulation Cooldown" 1 POP 05-E0-ES03, Re' vision 3 (October 10, 1988l, and 2 POP 05-E0-E503, Revision 0 (November 4,'1988), " Natural Circulation Cooldown With Steam Void in Vessel"

'1 POP 05-E0-E020. Revision 3 (December 3, 1987), and 2 POP 05-E0-E020, Revision 0 (November 6, 1988), " Faulted Steam Generator" OPMP04-RH-0001, "RHR Pump Maintenance," Revision 2

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-2-OPMP05-ZE-0300, "Limitorque NOV Motor Inspection and Lube," Revision 7 (General)

0PMP05-NA-0001, " General Electric 13.8 kv Breaker Tests," Revision 8 IPSP05-NI-0042, Revision 1, and 2PSPOE-NI-0042, Revision 1, " Power Range Neutron Flux Channel Calibration," (FCR 89-0923, dated March 28,1989)

IPSP02-RC-0410 " Delta T and Tang Loop 1 Set 1 ACOT (T 0410)," Revision 2 2TEP07-CV-0003, "CVCS Letdown Transient Test," Revision 0 1/2TEP07-FW-0018 "Feedwater Isolation Valves Solenoid Dump Valves Alternate Operability Test;"_ Revision 0/0 OTEP07-ZC-0001, "Determinating Tank Recirculation Time Test," Revision 1 l

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