IR 05000498/1989025

Insp Repts 50-498/89-25 & 50-499/89-25 on 890724-28 & 0807-11.No Violations or Deviations Noted.Major Areas Inspected:Action on Previously Identified Items & self-assessment Capability

ML20247D458
Person / Time
Site:	South Texas
Issue date:	09/07/1989
From:	Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247D457	List: IR 05000498/1989025 ML20247D452
References
50-498-89-25, 50-499-89-25, NUDOCS 8909140263
Download: ML20247D458 (9)

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5 l APPENDIX l U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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..NRC Inspection Report: 50-498/89-25 Operating Licenses: NPF-76 j 50-499/89-25 NPF-80  ;

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Dockets: 50-498 j 50-499

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-Licensee: Houston Lighting & Power Company (HL&P) l P.O. Box 1700 'j Houston, Texas 77001 l Facility Name: . South Texas Project (STP), Units 1 and 2 I Inspection At: 'STP, Matagorda, Texas Inspection Conducted: July 24- 8 and A gust 7-11, 1989

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Inspector: W .

W. M. McNeiH . Peactor Inspector, Materials Dat6 '

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and Quality Programs Section, Division of )

Reactor Safety j I

Approved: 8n np 1. Barnes, Chief, Materials and Quality

• 1l'7 l89 Date -!

Programs Section, Division of Reacur Safety Inspection Summary {

Inspection Conducted July 24-28 and August 7-11, 1989 (Report 50-498/89-25)

Areas Inspected: Routine, unannounced inspection of action on previously identified inspection findings and self-assessment capabilit q Results: The Nuclear Safety Review Board (NSRB) meetings appeared to be well documented and. resolution of concerns effective with some exceptions. The exceptions noted pertained to a lack of timely resolution of certain unreviewed safety question evaluations (USQEs) that had been referred back to the Plant -j Operations Review Committee (PORC) for additional information. The licensee 1 corrected this problem in the course of the inspection. PORC meetings appeared to be well documented. The agenda items were discussed in-depth and actions

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ft.11 owed up on with effectiveness. Review of Independent Safety Engineering Groa (ISEG) activities indicates that assessments were detailed and thorough in approach, with some documentation deficiencies noted. ISEG appeared, however; to be significantly below its goal"in performing direct plant observations. Additionally, only limited development of detailed recommendations i was noted to result from its assessment activitie N [

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Inspection Conducted July 24-28 and August 7-11, 1989 (Report 50-499/89-25)

l Areas Inspected: Routine, unannounced inspection of self-assessment capabilit Results: :The NSRB meetings appeared to be well documented and resolution of concerns effective with some exceptions. The exceptions noted pertained to a-lack of timely resolution of certain USQEs that had been referred back to the PORC for additional information. The licensee corrected this problem in the course of the inspection. PORC meetings appeared to.be well documented. The agenda ' items were discussed in-depth and actions followed up on with effective-ness. Review of ISEG activities indicates that assessments were detailed and thorough in approach, with some documentation deficiencies noted. ISEG appeared, however, to be significantly below its goal in performing direct plant observation Additionally. only limited development of detailed recommendations was noted to result from its assessment activitie . - _ _ _ _ - - _ _ _

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DETAILS 4

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1.- Persons Contacted

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• C. A. Ayala, Licensing Supervisor' . .

.. *S. R. Basu, Plant Operations Review Consnittee (PORC) Secretary

.~ J. ~ A. .Burack] Independent; Safety Engineering Group (ISEG)-Engineer M. K.>Chakravorty, NuclearLSafety. Review Board (NSRB) Administrator-

• R. W. Chewning," Nuclear Assurance Vice President

• D. J. Denver Nuclear Engineering Department Manager

• S. M.. Dew, Nuclear Purchasing and Mat.erials Management Manage <

.P.<D..Gaines', Procedure Analyst

• J. E. Geiger, Nuclear Assurance General Manager

.J. Hughes, Vendor Technical Information Program (VTIP). Coordinator

• W. J.. Jump,. Maintenance Manager

• D. R..Keating, ISEG Director

• A. K. Khosla, Licensing: Engineer >

• W.'Hs Kinsey,. Plant Manager E; M. Kruse, Secretary

• M. A. McBurnett, Licensing Manager G..N. Midkiff, Assistant to Plant Manage *G. L. Parkey, Integrated Planning & Scheduling Manager R. W. Patlovany, ISEG. Engineer

'*S. L. Rosen, Nuclear. Engineering & Construction Vice President'

• G. E. Vaughn, Nuclear Operations Vice President

• M. R. Wisenburg, Plant Superintendent NRC J. E. Bess Senior Resident Inspector, Unit 1

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R. J. Evans, Resident Inspector, Unit 1

• J. I. Tapia, Senior Resident Inspector, Unit 2 D. L. Garrison, Resident Inspector, Unit 2

• Denotes those persons that attended the exit interview on August 11, 1989.,

, The inspector also interviewed other licensee personnel during the ,

inspectio i

~ 2. . Action on Previously Identified Inspection Findings (92701)

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(Closed)OpenItem.(498/8801-13): ISEG was critical of the instrument and control (I&C) surveillance and time did not permit determination of what i actions were taken, j l

The inspector found that the ISEG observations of the I&C surveillance l activities were satisfactorily responded to in a memorandum dated June 10, ]

1988. This memorandum closed the issues identified by ISE j

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-4-I Licensee Self-Assessment Capability (40500)

The objective of this inspection was to evaluate the effectiveness of the licensee's self-assessment programs. In this regard, the inspector reviewed the activities of the NSRB, PORC, and the ISEG. The thrust of this inspection was to measure how effective these groups were in identification of concerns and following such to resolutio NSRB The activities of the NSRB were governed by a Nuclear Group Policy,

" Nuclear Safety Review Board," Revision 6. dated April 14, 1989. In addition, there was a NSRB manual which contained seven procedures and an operational philosophy. The NSRB was found to meet about twice a month. Fourteen meetings have been held in 1989. About half of the meetings were characterized as special meetings with only one or two agenda items. About once every month, regular meetings were held. Regular meetings differed from the special meetings in that a standard format of agenda items were reviewed. The NSRB membership was found to be as described in Technical Specifications (TS) plus Nuclear Engineering Department Manager, Nuclear Purchasing and Materials Management Department Manager, Plant Manager, and an outside member. The standard format meetings addressed such agenda items as:

Significant industry events Concerns ISEG assessments, reports, and investigations TS or license changes including TS Interpretations Unreviewed Safety Question Evaluations (USOEs)

NRC Inspection Reports and Violations

Level 1 Station Problem Reports (SPRs)

Deficiency Reports Nuclear assurance audit scopes and reports Plant tours The inspector reviewed the meeting minutes of 1989 in detail. The inspector attended Meeting 89-14 held on August 9, 198 Observations by the inspector were as follows:

The titles of persons assigned to NSRB have changed but the TS

, have not been changed to reflect the new titles. There are no general managers of STP Management and STP Operations Support, but an Administrative Support General Manager and a Nuclear Engineering and Construction Vice-President. HL&P informed the inspector that a TS change is in process to update the TS to reflect current title !

• A review of the qualification and training records in the NSRB files and the training procedure in the NSRB manual, found that l

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there appeared to be no requirement for or records of trainin .on such specific subjects as.10 CFR 50.59 and root cause analysi .7 * ,

In addition, a review of. site training; records found that there

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Lwere'apparently no records which reflect < training in 10 CFR 50.59 ifor five of the eight NSRB members and'two of:the five' alternate % ,

Also, there were apparently no records which . reflect training'in n root cause analysis for two membersiand one alternate. In that

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these types of_ training are'on significant elements of NSRB activities, an -improvement could be made'in the identification . "

of such as NSRB training; requirements and the maintenance o ,

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w, The meeting minutes were found.to be well documented and'

appeared to capture;in detail the discussions and comments.c '

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agenda items. . The use of a recording device to assure that all -

discussions are captured could be an: improvemen *-

-In"1989 NSRB meeting minutes have. documented the' identification 'j'

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ofq2 7"Open Items," 2 " Interest Items," and 28 " Recommendations."

The inspector reviewed the closure documentation for 15 of!the

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above items; The tracking;of items / concerns to resolution and

, '~ close out.was satisfactory.' The inspector did note that the-NSRB manual did not* address how each of these types of. concerns-

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were to be handled. Some concerns that were identified as e recommendations were:in reality handled as open.or interest items"in .that they were returned to the NSRB not just the'

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D chairman. Examples of.this were the. recommendations for off-line review of USQEs, and the recommendations-of USQE 88-0146'

'in Meeting'89-02, and USQEs 88-0142 and -0154-in Meeting 89-0 .Three concerns were found not classified as any of the above types (see Review Item 89-016-in 89-01 meeting and Review:

Items89-117 and -118~'in 89-05 meeting). NSRB procedures

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, could.be improved by' establishing the definition of these item

" types and the manner of resolution of the item * The inspector. selected.a sample of 27 USQEs after review of th most recent annual 10 CFR 50.59 report. A: review of NSRB's actions on these USQEs'found that NSRB could not conclude whether an unreviewed safety question existed for four USQEs and in each of these cases returned these USQEs to _PORC for additional-information. . These USQEs were: 87-061, dealing with a Final-Safety Analysis Report change on leak testing of' safety injection system accumulator discharge check valves, reviewed in the'

March 1988, 88-05 meeting;88-073, dealing with incompatibility of, hydraulic fluid used in main'feedwater isoletion valve operators, reviewed in the' June 1988, 88-09 meeting;88-077, dealing with a station modification of the addition of a' cross-tie line from the excess letdown to normal: letdown heat exchangers,

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reviewed in the July 1988, 88-12 meeting; and 88-090, dealing with changing the radiation monitoring system alarm setpoints,

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-6-reviewed in the August 1988, 88-13 meeting. The inspector was concerned about the effectiveness of these reviews if unaccepted USQEs were not resubmitted to NSRB in a timely manner. HL&P reviewed all USQEs submitted to NSRB and found one additional example, 88-45, of a USQE not resubmitted in a timely manne The four USQEs identified by the inspector and others (88-45 and more recent USQEs) were each entered into' the STP Licensee Connitment Tracking System (LCTS) for resolution by the end of the month. The PORC procedure was revised to require USQEs returned by NSRB for additional information to determine-if an unreviewed safety question existed to be then entered into the LCT Summary The NSRB meetings appeared to be well documented and resolution of concerns effective with some exceptions. The review of USQEs was not fully effective in certain cases, in that resolution of unacceptable USQEs was not timely.- The licensee corrected this problem in the

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course of the inspectio ~b.- PORC E The activities of the PORC were governed by Procedure OPGP03-ZA-0004, Revision 10, dated December 15, 1988, " Plant Operations Review Committee." The PORC met in regular weekly meetings and held special meetings as required by circumstances. At regular meetings typically 30 agenda iterns were. addressed, and at special meetings typically eight agenda items were addressed. As of this inspectici., about 70 meetings have been held this year. The PORC membership was found to be as described in TS. The meetings addressed such items as:

NRC Violaticas-

Administrative Procedures

.TS Interpretations Field Change Requests-

Station Problem Reports i Unscheduled items 1 The inspector reviewed the Meeting Minutes89-042 through -065 in detail. The inspector attended PORC Meeting 89-06 Observations by the inspector were as follows:

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A review of the PORC records of qualification and trainin0 Of

members and alternates found no records of specific training on I

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10 CFR 50.59 and root cause analysis. There were no l requirements established for such training in the PORC j procedure. It was noted that site training department records  ;

did reflect that 3 of 6 members and 3 of the 16 alternates were

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PORC procedure which addressed training in 10 CFR 50.59 and root cause analysis and the maintenance of such training record *

The PORC meeting minutes had sufficient detail to track discussions of agenda items. The inspector found PORC

"reconinendations" were implemented and " Action Items" tracked and closed in a satisfactory manne *

" Unscheduled items" were agenda items that had not been planned to be addressed and, as such, little or no prior distribution was made. The inspector did not observe this practice being abused, but did note that the 89-061 meeting had 13 unscheduled items. The inspector was concerned that there could be abuses of the practice of " unscheduled items."

The same sample of USQEs as identified above were reviewed by the inspector. There were no problems identified with the USQEs being reconrnended for approva The inspector did note that at the 89-067 meeting an interdepartmental procedure was reviewed by the PORC for which four of the six PORC members had also participated in the normal procedure review process, creating the potential for a lessening of member objectivit Summary The PORC meetings appeared to be well documented. The agenda items were discussed in-depth and actions were effectively followed u c. ISEG i

The activities of ISEG were found to be governed by an ISEG manual which contained five procedures and an operational philosophy. In addition, there were several interdepartmental procedures such as IP-1.42 -1.49, -2.2, and -8.30 which governed ISEG activitie ISEG was found to be staffed at the TS minimum of five with two additional positions unfilled at this time. The ISEG's activities included screening of operating experience reports such as NRC InformationNotices(IENs)andInstituteofNuclearPower Operations (INPO) Significant Event Reports (SERs), Significant

,. Operating Experience Reports (S0ERs), and Operating and Maintenance Reminders (0MRs). The ISEG's role as described in the procedures was for ISEG to screen for applicability to STP, identify issues and concerns to be addressed, identify questions to be answered, and recommend the appropriate organization for review of the repor ISEG reviewed Licensee Event Reports (LEPs) for NSR ISEG was L

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requOedbyitsLproceduresto'.performanannualovervieworauditof the process of review of operating events. ISEG was also to make

.pl ant' observations. Their goal was to spend-50 percent of the ISEG effort on plant observations, such as touring the plant, observin contro? room and local station operations, and monitoring maintenance and special evolutions. ISEG activities were defined in tasks and

. - documented in "Assessneent" reports. Currently, ISEG has assigned 32 tasks and issued " Assessment" reports on about' 20 of the task The inspector's observations on ISEG activities were as follows:

It appeared that ISEG did not use all NRC issuances and. industry advisories in that it was not on the regular distribution for NRC Bulletins and Generic Letters and vendor information such as service bulletins, service information letters, etc. .NRC Bulletins and Generic Letters were screened by the Operations Support Licensing Division (OSLD). Vendor information was 1 administered under the Vendor Technical Information Program which did not interface with ISEG. It would. appear tha a significan_t improvement.could be made in the expansion of input information to ISE o

• For those NRC issuances and INP0 information that ISEG did get regular distribution, ISEG only screened the information for

~O SLD'and did not review the detailed recommendations made by the other organizations on make detailed recommendations of its ow *

ISEG'did a significant number of assessments.at the request of NSRB and plant management. A review of two recent assessments of SERs, performed at the request of NSRB (89-30 and -32 assessments), found the assessment limited to the root cause analysis and corrective actions taken by other licensee The assessments did not address the impact of the problems described in the SERs at STP. The root cause analysis that was performed was quite thorough and well don * The review of LERs on behalf of NSRB appeared to be limited to the LER and the associated SPR. Other sources of infonnation, such as interviews, were not used. An example of this was LER 2-89-011, a reactor trip caused by personnel error in the use of the plant heat up procedure checklis * The review of four recent LERs, 1-89-009, 2-89-009, 1-89-010, and 2-89-010, by the inspector found that although significant coninents appeared to be made in regard to the root cause analysis in the LER, these comments were sent to the originating organizations for consideration with no response require * Plant observation activities appeared less than the 50 percent goal, in that only two such assessments have been completed and one in progress for this yea ,

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• -In addition to the above, there were a number of minor .

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observations by the inspector... For example, there appeared to 'l '

be no measures in procedures to assure that. plant observations were completed for a broad spectrum of activities. The inspector reviewed a sample of three' assessments. The inspector found i that Assessment 89-25 was not in the standard fonnat making it -)

- difficult to determine what were the recommendations, and '1f-such ~were resolved. . Assessment 89-26 had: a sumary statement which identified that there were no recommendations when the

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details of the report identified that there were five, and:there l 1, appeared to be no records of resolution.in the files of the- q recommendations. The ISEG activities on SOER 88-2 were reviewed >J at the request:of.the past ISEG Directo It was noted that -

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this activity was not documented as an assessment but only a NSRB presentation. Although the presentation'did address the-

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, barriers at STP, which would prevent precriticality, there appeared to be no detailed recommendations made by ISEG and subsequent followu i Sumary

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Review of ISEG activities indicates that assessments were detailed and thorough in approach,'with some documentation deficiencies noted. ISEG appeared, however, to be significantly below its goal in performing direct plant observations. Additionally, only limited

. development of detailed recommendations was noted to result from its assessment activitie No violations or deviations were identified during this inspectio . Exit Meeting An exit meeting was held on August 11, 1989, with those individuals denoted in Section 1 of this report. At this meeting, the scope of the inspection and the findings were sumarized. The licensee did not identify as proprietary any of the information provided to or reviewed by the inspecto I l

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