IR 05000498/1989029
| ML19325D382 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/12/1989 |
| From: | Ray Azua, Bundy H, Murphy M, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19325D379 | List: |
| References | |
| 50-498-89-29, 50-499-89-29, NUDOCS 8910230174 | |
| Download: ML19325D382 (9) | |
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i APPENDIX l
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: S0-498/89-29 Operating License:
NPF-76 l
50-499/89-29 NPF-80 Dockets: 50-498
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50-499
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s Licensee: Houston Lighting & Power Company (HL&P)
P.O. Box 289
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Wadsworth Texas 77483
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Facility Name: South Texas Project (STP), Units 1 and 2 Inspection At: STP, Matagorda County, Texas
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Inspection Conducted: September 11-15, 1989
Inspectors:
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M. E. Murphy, Reactor Inspector, Test Programs Date
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Section, Division of Reactor Sefety
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[n P. F. Bundy, ReactorfInspector, Test Programs Date'
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Section. Division of Reactor Safety
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AN&4@El M/l//Ba
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" Rr-V. Tuva, Re' actor Inspector. Test Programs Date /
Section, Division of Reactor Safety
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Accompanied By: ~
W. C. Seidle, Chief. Test Programs Section Division of Reactor Safety J. P. Jaudon.. Deputy Director, Division of Reactor Safety ru e
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/d 2 87 Approved:
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l W./C.(SeiqTe, Chief, Test Programs Section Date Dfvision 6f Reactor Safety 8910230174 sof 01(p F'DR ADOCK 05000498 PDC
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' _ Inspection Summary l
Inspection Conducted September 11-15',>1989 (Report 50-498/89-29)
, Areas Inspected: Announced team inspection for system entry retests in the areas of nodifications, temporary modifications, and maintenance activities.
l Results: The licensee has a strong program for determining the need for retest and the. identification of the appropriate retest typet the licensee also had a good program for development and performance of adequate procedures for retests of structures, components, and systems following plant modifications and maintenance activities. One minor weakness was identified in that there were no documented guidelines for recognizing, planning, and developing retests for an extensive modification that would require an integrated systems post-startup retest. The present engineering experience level offsets the immediate need for such guidelines, but with career advancement and attrition this experience
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may become diluted.
No violations or deviations were identified.
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Inspection Conducted September 11-15, 1989 (Report 50-499/89-29)-
Areas Inspected: No inspection of STP, Unit 2, was conducted.
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DETAILS 1.
Persons Contacted
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HL&P
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. R. Chewning Vice President, Nuclear 0perations
S. Rosen, Vice President
- J. Neeley, City of Austin
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- D. Chamberlain Plant Enginee'r
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- C.'Ayala, Supervisory Engineer
- V. Simonis, Manager, Plant Operations Support r
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- J. Loesch.. Manager, Plant Operations
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- A. Hamson, Supervising Licensing Engineer
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- W. Kinsey, Plant Manager
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- W.' Jump, Maintenance Manager
- A. Khosla Senior Licensing Engineer
- J. Minor, Construction Engineer J
- R. Munter Division Manager,. Support Engineering
- P. Desa, Ounlity Cngineer
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- W. Blair,. Manager Maintenance Support
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'*M. Wisenburg,' General Manager. Nuclear Safety Review Board
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- M. McKay Independent Safety Engineering Group'
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- H. McBurnett, Manager, Licensing
- S. Hubbard, Quality Control Supervisor
- J. Green, Manager, Inspection and Surveillance
- D. Brown, Manager, Support Construction Department
- A. McIntyre, Manager Support Engineering
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- S. Dee, Manager Nuclear Purchasing Material Management
- T. Jordan, Manager. Plant Engineering
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- G. Parkey, Manager, Integrated Planning and Scheduling
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- J. Lovell, Manager. Technical Services
J. Beers Supervisory Engineer C
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C. Grantom, Plant Engineer
W. Mutz, Manager, Strategic Planning
.l J. Gruber, Scheduler
D. Rencurrel, Plant Engineer M. Ahumada, Plant Engineer
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L R. Condit, Supervisor, Mechanical Planning J. Garcia Lead Planner Electrical Planning
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M. Murray, Supervisor, Instrumentation and Control Planning Bechtel
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- C. O'Neil, Manager, Project Engineering NRC
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- J. Tapia, Senior Resident Inspector
- J. Bess, Senior Resident Inspector
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- R. Evans, Resident inspector
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The inspectors.also interviewed other licensee employees during the
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inspection.
- Denotes those' attending the exit meeting conducted on September 15, 1989.
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Inspection Objectives and Method
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l The overall objective of this inspection was to determine the licensee's (
performance in the area of system entry retest identification,
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documentation, and conduct.
i t-To accomplish this objective, the inspection detennined that retest requirements were evaluated during modification and maintenance planning
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l and that the retest procedures met regulatory requirements, comitments, and
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industry guides or standards.
It was also determined that retest requirements were considered for all system boundary violations. The
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inspection also verified that the retests proved operability and assured
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that the design basis was satisfied for structures, systems, and components that were modified or subjected to maintenance during thi.s refueling outage.
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The inspectors reviewed the licensee's administrative procedures for j
modifications and maintenance.' The followir.g procedures were found to i
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define,the retest program, estab)ish responsibilities, and provide
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procedure develcpment:
IP-3.1Q " Plant Modifications," Revision 6
OPGP03-20-0003, " Temporary Modifications and Alterations," Revision 9
OPMP02-ZG-0006, " Work' Implementation," Revision 1-
OPGP03-ZE-0020. " Post Maintenance Testing Program " Pevision 1
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OPGP03-ZM-0025,," Maintenance Testing Program," Revision 0
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l Work items scheduled for this refueling outage were assessed and the I
inspectors selected 5 modification packages, 5 temporary modification packages, andl32 maintenance work requests for detailed review..
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3.
Inspection Findings Sumary
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The'11censee was found to have a strong program for identifying, planning, developing', and performing retest procedures.
Retest requirements were
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adequately addressed in the areas' of modifications, temporary modifications,
and maintenance work. Responsib111 ties are well defined, and personnel training and experience was found to be very good at all;1evels of
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involvement. One minor weakness was identified in that there were no documented guidelines for recognizing, planning, and development of retests for an extensive niodification that would require an integrated
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systems post-startup retest. The > resent engineering e::perience level offsets the,immediate need'for suc1 guidelines, but with career advancement
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and attrition this experience level will become diluted.
No violations or deviations were identified during the inspection.
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Modifications (72701)
During this part of the inspection five plant modification (PM) and
associated retest packages were reviewed by the inspectors to ascertain that appropriate retest requirements had been incorporated in the design and work planning documents. The most extensive modification PM-88162-l involved replacement of all small bore cast aluminum-bronze valves, i
fittings, and pipes in the Train C essential cooling water (ECW)' system
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with forged components. Leaks had developed during operation as a result
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of dealloying of the material. The inspector found that appropriate tests i
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had been specified and perfonned to assure operability of the system. An in-service pump test was performed in accordance with Procedure PSP 03-EW-0010
"ECW Pump In-Service Test," to assure no change in system flow had occurred.
Hydrostatic tests were performed to verify system integrity under
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Test EW-89021890 and -89023386 prepared in accordance with the requirements'
of Procedure OPGP03-ZE-0027 Revision 2. "ASME Section XI Post-Maintenance
Pressure Tests."-
Appropriate tests had'also been identified and perfonned for the other PMs
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reviewed by the inspector. They were:
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PM 88246, " Reroute RWST to Charging Pump 8-inch Piping," approved
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August 18, 1988. Tests performed pursuant to PM 88246 were Pressure Test 89041798 prepared in accordance with Procedure OPGP03-ZE-0027
and a flow test in accordance with instructions in the work.
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authorization document.
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PM 88276, " Add Control Room Indication to Containment Purge Sample Selection Valves," approved October 13, 1988. Tests performed pursuant to PM 88276 were Verification Instructions in Data Base Change Request 89-AM-0002, Verification Instructions in Computer
Software Change Request 89-AM-019, and Test Package 89032963 including instructions for testing flowpath and ERFDADS display.
PM 87043, " Chilled Water System Second Containment Automatic Isolation
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Valve." Tests performed pursuant to PM 87043 were-Procedure 1 PEP 07-CC-0001, " Post Installation Test for Valve DICCFV0862,"
performed September 7, 1989; Local Leak Rate Test (LLRT)
Procedure OPSP11-CC-0002, " Penetration M26," performed September 1, 1989; Test Package 89040768 " Inservice Leakage Test for Valve B1CCFV0862;" Work Request (WR) CC83317. " Electrical Checks and Setup of Valve B1CCFV0862;" LLRT Procedure OPSP11-CC-0005, " Train C;"
and, inservice leakage test for Valve A1CCFV0864.
PM 88336, " Delete Boric Acid Flow Path Through Valve CV-215." Test Package 005394-EP-02, " Hydro Package for PM 88336 per Procedure OPGP03-1.E-0027-1" was specified.
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In each instance,* operability of the component and/or system would have been verified upon completion of the required testing. The boundaries
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established for the testing were appropriate. Test exceptions were properly identified and dispositioned. The tests reviewed contained t
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appropriate system restoration instructions as well as turnover to operations procedures for the modified system. The tests reviewed encompassed mechanical, electrical, end instrumentation and control testing. The inspector noted that provisions had been made to revise instructions, procedures, and drawings prior to operation of the nodified
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systems. Timely retraining had also been specified when required.
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Ten.porary Modifications ' (72701)
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The inspectors reviewed'the licensee's temporary modification program, which was described in Administrative Procedure OPGP03-ZO-0003, Revision 9. " Temporary Modifications and Alterations."
As in permanent plant modifications, the temporary rodification request can be initiated by anyone. These modifications undergo a progransnatic as'
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well as a license compliance review to determine if other evaluations, such as, as low as reasonably achievable (ALARA) or environmental,.are necessary. The Technical Specifications and the associated final safety i
analysis report chapters are also reviewed to determine the impact, if any, the modification may have and what restrictions may apply.
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addition, a 50.59 review is perfomed when it is determined that one is required. Finally', a decision is made as to whether post modification
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testing is needed, and a justification is provided to define the reason
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for the decision.
The inspectors reviewed several temporary eadification packages:
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T1-0W-89-07, "TGB Oily Waste system Samp No. 2," approved
February 25, 1989.
Provided ability to process high ph influent into the oily waste sump.
Installed and verified on February 26, 1989; Work Control Document CWR 004463.
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T1-PH-89-035 " Blind Flanges on Electrical' Penetrations 3E261EEP0003
i and 3E261EEP0004." approved August 6, 1989. Modify to allow control
cables to penetrate the RCB and still maintain containment integrity
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(see paragraph 7).
Installed and verified on August 9, 1989; Work
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Control Document WR PH-84668-EM-01.
T1-CR-89-017 " CARS Pump Suction Header" approved.May 5, 1989. Attached
drain connection to containment atmosphere recirculation system (CARS)
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inlet separator drains, to remove water accumulation from-the CARS pump suction line. Installed and verified on May 6,1989;L Work Control Document WR CR-80767.
- T1-EH-89-018. " Turbine Generator," Approved May 7, 1989. Swap servo
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amp cards to allow GV-1 to be the controlling valve'at full turbine
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load.
Installed and verif ted on May 12, 1989; Work Control
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Document WR MS-79737.
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T1-EW-89-022. "ECW Electro-Hydraulic Control. Valve C1EWPV6874 and I
CIEWPV6906," approved' June 16, 1989. Actuators to be removed and replaced by temporary handles'(locked open). : Installed and verified i
on June 16, 1989; Work Control Document 76089-EP-01.
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The' modification packages were found to be complete and met the requirements set forth in Administrative Procedure OPGP03-ZO-0003. The inspector also verified that each package had been reviewed as identified by the appropriate signatures. The post modification tests were reviewed for adequacy, and for those tests that had ~already been performed, it was found that the results met' the acceptance criteria set forth in the test procedures. For those modifications that were exempted from post.
i modification testing, the inspectors reviewed.the licensee's reasons for i
the exemptions.
In addition, the inspectors also inspected'some of the
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modifications to. verify the adequacy of their installation.
In general, the licensee's temporary modification program was found' to be
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adequate, providing a comprehensive review process which would minimize j
the chances of error.
It.was noted though that'although the installation
' procedures for the temporary modifications provided sufficient information'
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for adequate installation, some points could be open to interpretation.
It was mentioned to the licensee that' additional detail in procedures may preclude any possible erroneous interpretation, thus' reducing the chances
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that a temporary modification may be inadequately installed.
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Fihally..as discussed in s'ubsequent conversations with the licensee.-
' temporary modifications should be analyzed on a' case by case basis, i.e.,, *
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the future, it is necessary that that package be resubmitted through-the
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original review process, including a design review.,This is important
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because possible changes in plant design or in regulatory requirements '
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may invalidate the design basis used for the original temporary-
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modification package. The licensee agreed and stated'that that was the J
intent of the temporary modification program.
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Maintenance (62700,62702)
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l-The inspectors reviewed the licensee's maintenance program, as described
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in Administrative Procedures OPGP03-ZE-0020 " Post Maintenance Testing o
Program," and OPGP03-ZM-0025, " Maintenance Testing Program."
Anyone onsite may initiate a WR, which describes a problem and how it was.
discovered. The WR is then forwarded to the maintenance department through the shift supervisor. Maintenance support planning processes the WR, evaluates' the problem, walks the job down, determines the level of work l
instructions, resource availability, interdepartmental interfaces, and post maintenance testing. A work order.is produced and a complete work package is forwarded to the responsible craft. Post maintenance testing is performed by the craft after the work is completed.
Final review of the completed work package is accomplished bl! the shift supervisor and an. independent
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post review group in the maintenance department.
Quality control (QC)
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involvement is' assured, if required, when the work package is initially
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developed because the quality organization is required to review the
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package for QC inspection and hold points'. The inspectors reviewed a
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total of 32 work packages, some completed, some in process, and the rest
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l scheduled but not worked. Of the packapes reviewed, mnst were planned corrective maintenance, some were preventive maintenance, and some.wcre
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scheduled refueling outage surveillances. There is a fourth category
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called " emergent work," this is defined as work' resulting from an expansion i
of the scope of.the original item. The inspectors reviewed this area
carefully and determined that the " emergent work" is treated the same as an original.WR, and it receives the sane level of' attention with respect to post-maintenance retest requirements.
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Interviews were conducted with selected planners f rom each of the three maintenance areas:, mechanical, electrical, and instrumentation.and
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control. These interviews confinned the procedural process and the level of experience in the planning departments.
The review of the administrative procedures and work packages, along with
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j the interviews, confirmed that the licensee's program provides documented guidelines for the evaluation, identification, and development of retests appropri' ate to the required work to restore the structures, components, or systems to an operational condition.in keeping with the functions required by the cesign basis. Provisions are made for. review and evaluation of completed tests to ensure that test results meet the established j
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acceptance criteria. Provisions are also in place to' resolve test i
deviations and accomplish retests where required.
Procedures and
responsibility have been established for returning equipment and systems to service, y
One minor weakness was identified when it was-determined ~ that there were no documented guidelines for evaluating or identifying a retest that would
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complicated or extensive work activity could result. in the need for integrated system testing or require post startup testing.- None of the work items scheduled for this outage were found to be this type of'
activity. Discussions with licensee representatives revealed that the high degree of experience in the engineering groups was relied on to provide the expertise needed to recognize and handle this type of retest.
The licensee representatives acknowledged that this' level of experience will become diluted with career advancements ano attrition of personnel.
They agreed to review this area carefully and to consider the development of documented guidelines.
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Followup on Previously Identified Inspection Findings' (92701)
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(Closed) Unresolved Item (498/8927-02): Adequacy of Temporary Modification Installation - For refueling operations. Technical
3pecification 3/4.9.4, " containment Building' Penetrations," stated that
" containment penetrations. shall be... closed by an isolation valve,
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blind. flange, or manual valve... and that each containment penetration l
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of this Technical Specification is to guarantee that containment integrity
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is maintained during refueling operations.
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Temporary Modification T1-PH-89-035 required the removal of several
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containment penetration blind flanges, and replaced them with modified.
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flanges. The design of the modified flanges was based on allowing control i
cables to penetrate the reactor containment building and still maintain-
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containment integrity during refueling operations. This temporary j
modification package though, did not require any post modification
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installation testing.
The inspector reviewed the design of the temporary modification and found i
that the modified flanges were designed to withstand a reactor containment d
building pressure in excess of the worst case accident pressure for loss of residual heat removal during refueling operation.
The inspector also reviewed the temporary modification package. One item reviewed very closely was the handwritten installation procedure.
It was detemined that although the procedure for installation cf the modified flanges was general in nature, it provided sufficient information for the
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' work.to be completed adequately.
In addition, it was noted that, although
no hold ~ points for QC signoff were available, there were several signoff
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requirements for the cognizant engineer who in turn inspected the work that hao been completed. The inspector interviewed the cognizant engineer
'and some of the personnel. involved in the installation of the ruodified t
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It was determined that the licensee placed sufficient attention to detail to instali the modified flange adequately. Because of this deteimination coupled with the margin of safety provided by the modified flange design, t
the inspector concluded that the licensee's decision not to'twrform a post l
modification installation test was acceptable. This item wu discussed I
with the Office of Nuclear Reactor Regulation, who also found the licensee's l
actions and conclusions to be acceptable..
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Exit Meeting An exit meeting was held September 15, 1989, with the individuals noted in paragraph 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 inspectors.
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