IR 05000498/1990021
| ML20043G787 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/14/1990 |
| From: | Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20043G786 | List: |
| References | |
| 50-498-90-21, 50-499-90-21, NUDOCS 9006210133 | |
| Download: ML20043G787 (9) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report: 50-498/90-21 Operating Licenses: NPF-76 i
50-499/90-21 NPF-80
Dockets: 50-498 50-499 Licensee: HoustonLighting&PowerCompany(HL&P)
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P.O. Box 1700
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Houston, Texas 77251 Facility Name: SouthTexasProject(STP)ElectricGeneratingStation Units 1 and 2 l
Inspection At: STP,Wadsworth(MatagordaCounty), Texas
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i Inspection Conducted: May 21 through 25, 1990
Inspector:
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GMz/90 D. R. Hunter, Senior Reactor Inspector Date Operational Programs Section, Division of
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Reactor Safet
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Approved:
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/!!apJliardo, Chief, Operational Programs Date
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Sel'.iod, Division of Reactor Safety
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i Inspection Summary L
Inspection Conducted May 21 through 25, 1990 (Report 50-498/90-21;50-499/90-21)
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Areas Inspected: Routine, unannounced inspection of previously identified-Inspection findings, including the items associated with the emergency operating procedure enhancement program.
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Results: Within the areas inspected, no violations or deviations were identified. The review of the actions associated with the emergency operating procedure (E0P)enhancementprogramrevealedthatthelicenseehadsubstantially
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completed the E0P upgrade program; however, additional review and walkdown by
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the NRC will be required to address the overall effectiveness of the E0P enhancement program. Additional emergency lighting deficiencies and environmental matters, initially identified in 1988 and 1989, were being resolved to coincide l
with the implementation of the' enhanced E0Ps in August 1990.
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The inspection revealed that the off-normal and alarm response procedure enhancement program was part of the overall procedure enhancement program. The completion of the off-normal and annunciator enhancement program was scheduled for completion in early 1991. The licensee had made a number of improvements
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in the off-normal procedures to ensure adequate coverage of postulated equipment
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failures and reactor plant system perturbations.
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3-DETAILS
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PERSONS CONTACTED
- G. Vaughn, Vice President, Nuclear Operations
- *R. Chewning, Vice President Nuclear Support
- M. Wisenburg, General Manager, A',sessment/NSRB
- T. Jordan, General Manager, Nuciear Assurance
- D. Denver, Manager, Plant Engineering
- A. McIntyre, Manager, Support Engineering i
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- J. Loesch, Manager, Plant Operations
- W. Jump, Manager Maintenanet-
- S. Dew, Manager, Mechanical Maintenance
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- J. Lovell, Manager, Technical Services
- D. Leazar, Manager, Plant Programs
- E. Stansel, Manager, Plant Computer Division
- M. Ludwig, Manager, Participant Services
- 0. Keating, Director, ISEG
- L. Weldon, Manager, Operations Training
- C. Bowman, Manager, Operations Support
- A. Harrison, Supervising Engineer, Licensing
- U. Patil, Supervising Engineer, Mechanical / Nuclear Support
- J. Labuda, Supervisor, Fire Protection
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- A. Khosla, Senior Engineer, Licensing
- S. Phillips, Licensing Engineer B. Doss, Supervisor, Simulator Support T. Norris, Operations Support F. Maldonado, Operations Support
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NRC
- J. 1. Tapia, Senior Resident Inspector
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- M. E. Murphy, inspector
- J. E. Gagliardo, Chief, Operational Programs Section
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Other members of the technical and administrative staff were also contacted.
- Denotes those attending the management exit on May 25, 1990.
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FOLLOWUP OF PREVIOUSLY IDENTIFIED INSPECTION FINDINGS (Closed) Violation (498/8915-01; 499/8915-01):
Inadequate Off-Normal Operating'
Procedure OPOP04-Re-0001, " Loss of Automatic Pressurizer Pressure Control," Revision 0, did not adequately address the expected loss of pressure control or the failure of a reactor protection channel during low temperature - low pressure operations, t
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-4-The inspector reviewed the updated procedure (FCR 89-1613, dated June 14, 1989; and FCR 89-1725, dated June 30,1989), which provided guidance regarding the cold overpressure mitigation system and the Technical Specifications requirements, and discussed the corrective actions with the licensee. The licensee had
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established additional procedures and revised procedures to enhance the scope and content of the off-normal procedures. The licensee recently completed a survey as part of the procedure enhancement program and found the need for
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additional off-normal procedures. The licensee planned to complete the enhancement of the off-normal and annunciator response procedures in early 1991.
Theinspectorreviewedthreeadditionaloff-normalprocedures(listedin Attachment)whichhadbeenupgradedaspartoftheinitialoff-normalprocedure
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enhancement program. The inspector also reviewed the backup documentation used
-to develop these procedures. The procedure content and format were addressed
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by Procedure OPOP01-ZA-0007 (Addendum 4).
Section 9.0 of Procedure OPOP01-ZA-0007 specifically addressed the " Preparation, Review, and Walkdown" requirements for certain procedures, including off-normal and annunciator response procedures. The procedure requirements did not-specifically address an in-plant and simulator validation, as appropriate.
This matter was discussed with a licensee representative for consideration.
The inspector noted that the annunciator response procedure content and format were addressed-in Addendum 5 to OPOP01-ZA-0007.
The inspector has no further questions regarding this matter and the violation is considered closed.
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_ Closed)Openitem(498/8927-01;499/8927-01): Discrepancy Between Design (
Change Checklists An apparent procedural weakness was identified regarding the level of detail required by the modification process -- major and minor modifications.
TheinspectorreviewedthechancetoProcedureOPGP03-ZE-0031,"DesignChang[ek]),
ImplementationAfterTurnover"(FCR 89-3337 associated with Mods / Checklist
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and noted that the change provided uniform processing of the modifications.
The inspector has no further questions regarding this matter and this item is
considered closed.
(Closed)0)enItem(498/8927-02;499/8927-02): Nuclear Safety Review Soard IN5R3) Independent Review of Safety Evaluations For Temporary Modifications A temporary modification associated with a reactor containment spare penetration was deemed to require neither a 10 CFR 50.59 safety evaluation or an independent review by the NSRB to verify that no unreviewed safety question was involved.
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-5-The inspector reviewed the licensee procedures associated with temporary modifications and discussed the modification process with licensee representative's.
Procedure OPGP03-Z0-0003, " Temporary Modifications and Alterations," Revision 9, i
wasupgraded(FCR 89-2941) to require classifying a temporary modification (safety-related, "yes" or "no"; or quality-related, "yes" or "no") and to an enhanced and documented 10 CFR 50.59 screening evaluation (IP 3.20 Q-2) perfo
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review process for a proposed temporary modification included the system engineer, a second engineer, the plant engineering manager, the plant and safety analysis group, and the plant manager (for temporary modification classified as safety-related or requiring a 10 CFR 50.59 safety evaluation).. Additionally, document reviews and discussions revealed that if the 10 CFR 50.59 safety evaluation was required to be performed, the administrative controls required the proposed f
modification to be reviewed by the onsite review committee and approved by the
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plant manager. The reviews of such reviews were provided for review by the offsite comittee during a regularly scheduled meeting.
The inspector has no further questions regarding this matter and this item is conridered closed.
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(0 pen) Open item (498/8868-06; ',99/8868-06):
Environmental Conditions Associated with E0P and Off. Normal Procedure Actions
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The open item concerned the lack of a study to determine the expected postaccident environmental conditions (rediation and temperature) in the plant areas where operator actions were required.
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Discussions and document reviews revealed that the survey of the areas in question to determine the radiation exposures was nearing completion in response
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to a request for action (RFA 90-0617, dated April 24, 1990, and revised on May 18, 1990). The E0P in-plant validation walkdowns identified specific operator actions and the locations and times for accomplishment of these i
actions. The licensee projected the completion of the engineering response-t regarding the radiation exposures to operations personnel to be completed in late June 1990.
This matter will remain open pending NRC review of the licensee study associated with the environmental conditions.
(0 pen)OpenItem(498/8708-61):
Lack of Documentation of Deviations From the-Westinghouse Owner's Group (WOG) Emergency Response Guidelines (ERGS)
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A number of deviations from the WOG ERGS were not adequately. documented and
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justified on the step justification / verification forms.
The inspector reviewed Procedure OPOP01-ZA-0016. " Emergency Operating Procedure
Writer's Guide," and Procedure OPOP01-ZA-0017, "En.crgency Operating Procedure I
Revision and Implem mtation," Steps 2.4 and 3.4 respectively, which addressed the' development, revision, and documentation of the emergency operating procedure
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1.'ach of the three draft E0Ps and documentation packages selected for review contained E0P technical guidelines, which addressed the WOG ERGS, Revision 1A, and other connitments and requirements, including the South Texas Project ElectricGeneratingStation(STPEGS),E0Pstepnumber,theUOGERGstepnumber,
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and the basis for deviation.
The STPEGS E0P technical guidelines reviewed ditt not adequately address the E0P procedure " purpose' nor the "symptomr or entry conditions" sections which included deviations from the WOG ERG',.
This matter was discussed with a licensee representative and provided for consideration.
This item will remain open pending the compledot of the NRC review and field
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walkdown during a subsequent inspection.
(0 pen) Open Item (498/8868-01; 499/8868-01): Upgraded E0Ps Written to I
Revision I A of WOG ERGS, the E0P Writer's Guide, and the E0P Preparation
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Procedure This open item noted the need to upgrade the STPEGS E0Ps to correct ideatified techniR, and human factors deficiencies and to incorporate required technical and administrative controls.
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The inspector reviewed Procedure OPOP01-ZA-0016, " Emergency Operating Procedure Writer's Guide," Step 2.3, which addressed the drafting of the E0Ps using the
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appropriate documents, including the current revision of the WOG ERGS; and Step 2.4, which addressed the development of the E0P technical guidelines.
The inspector reviewed three draf t E0Ps (listed in Attachment) and related documentation packages to ascertain that the E0P technical guidelines followed the WOG ERGS, Revision IA, and that deviations from the WOG ERG were documented. Except for the item noted above (purpose and symptome or entry conditions), no other deficiencies were identified.
The inspector has no further questions regarding this matter; however, this
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item will remain open cending the completion of the HPC review and field walkdown during a subsequent inspection.
Qpen) Violation (498/8868-02;499/8868-02):
Inadequate Emergency Operating Procedures
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The licensee failed to have adequate procedures to prepare, verify, and validate the STPEGS E0Ps.
The inspector reviewed the specific administrative procedures which controlled the preparation and upgrade of the STPEGS E0Ps and three draft E0Ps and documentation packages generated to support the STPEGS E0P _
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-7-i Section 2.0 of Procedure OPOP01-ZA-0016 addressed the E0P developinent process,
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including the reference to the WOG ERGS; the safety analysis report (SAR),
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Technical Specifications, plant drawings, and action tracking systems; set point documents, calculations, and WOG ERG basis document; E0P numbering,
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format requirements, and writing style; E0P walkdown activities; and the a
generation of STPEGS E0P technical guidelines.
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Section 4.0 of Procedure OPOP01-ZA-0017 addressed the E0P multidiscipline L
verification process, including E0P walkdowns, technical reviews, interdepart-
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c ment reviews (plant, support, and nuclear engineering), and an independent.
l operational review of the nuclear training department. Section 5.0 addressed
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' the E0P validation process, utilizing a team approach, including in-plant-P validation, simulator scenario validation, and simulator validation performance.
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The validation required the use of a human factors specialist,
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b The inspector's review of the thre draft E0Ps and documentation packages revealed that the procedures were written in accordance with the approved
- writer's guide and had been verified and validated as required. Each package
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reviewed contained the following:
STPEGS E0P Tecnnical Guidelines, Revision 0
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ProcedureApprovalForm-(0PGP03-ZA-0002-2)
r LicenseComplianceReviewForm(OPGP03-ZA-0003-1)
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i L'alkdown Check 11st (OPOP01-ZA-0017-7)
Procedure'ReviewandCammentForms(OPGP03-ZA-0002-3)
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Engineering Review Checklist (0P0F01-ZA-0017-3
TechnicalReviewChecklist(OPOP01-ZA-0017-5)).
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. Westinghouse Review Comments and Resolution M
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In-Plant Validation Checklist (OPOP01-ZA-0017-4)
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SimulatorValidationDeficiency/ResolutionForm(OPOP01-ZA-0017-7)
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-The review of E0Ps-0 POP 05-E0-E020, " Faulted Steam Generator Isolation," Step 5, j
and OPOP05-E0-EC21, " Uncontrolled Depressurization of all Steam Generators,"
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- Step 4, revealed that the operators were required to " Check AFWST tevel -
I Greater than 138,000 Gallons-(26 percent)" and if necessary, the " Response Not
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Obtained" stated " Initiate makeup to the AFWST per 1(2) POP 02-AF-001, j
' Auxiliary Feedwater,' to prevent inventory problems during cooldown." The
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auxiliary feedwater procedure addressed the use of the condensate dump pumps.
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Discussions revealed that the dump pump was not a safety-related-pump with
= Actrical power from the Class 1E (emergency diesel generator) buses. A loss
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.uf offsite power would result in the-lack of capability to provide makeup to
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the auxiliary feedwater storage tank (AFWST). This discrepancy was discussed
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with'a licensee representative and provided for consideration.
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1The inspector noted that the licensee had directed Westinghouse to perform an inderendent review of the enhanced E0Ps during the initial verification
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procbss. The comments provided by Westinghouse were addressed by the licensee.
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The inspector-noted that changes made to the E0Ps subsequent to the Westinghouse reviews-(after December 1989) as a result of continuing reviews, in-plant
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walkdown validations,'and simulator validations had not received a similar
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b-8-review by Westinghouse. A licensee representative stated that the changes made subsequent to the Westinghouse review were processed in accordance with the normal procedures to address the STPEGS E0P technical guidelines and that the changes were compared to Westinghouse coments.
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The in-plant-validations identified additional concerns regarding emergency lighting in certain areas'of the plant. Discussiens revealed that the licensee updated the previous' modification requests regarding emergency lighting.
Additionally,'the licensee stated that six new emergency storage locker-kits were being installed and outfitted to provide battery-powered lanterns and
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needed items (tools, procedures, etc.). The additions were scheduled to be completed prior to implementation of the enhanced E0Ps.
l Document reviews and interviews revealed that the quality assurance (QA)
department and the independent safety engineering group (ISEG) were included as part of the in-plant vaiidation activities. However, the involvement of QA, ISEG, or.other groups in the overview of the ongoing E0P upgraded program was not apparent. The licensee indicated that a comprehensive QA audit of the E0Ps i
was scheduled for the later part of 1990, subsequent to implementation of the enhanced E0Ps.
Document reviews and discussicas revealed that the enhanced E0Ps were nearing I
completion. Editorial review of the E0P packages by the plant operations
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manager was in progress so that training of operations personnel prior to'an August 1990 implementation date could be accomplished.
The inspector has no further. questions regarding this matter; however, this
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item will remain open pending the completton of the NRC review and field f
walkdown of relected E0Ps during a subsequent inspection, j
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EXIT INTERVIEW The inspector sumarized the inspection scope and findings with the individuals
. identified in paragraph 1 on May 25', 1990. The inspector comenteo regarding the additional needs (emergency. lights, tools, etc.) identified during the E0P-enhancement process and the environmental survey (nearing completion). The
inspector noted that the initial review of the E0Ps included Westinghouse;
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however, the changes made to the E0Ps in 1990, had not received a similar review.
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or.ISEG was-limited. The licensee acknowledged the coments. No information rev'ewed by the inspector was identified by the licensee as proprietary.
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ATTACHMENT DOCUMENTS REVIEWED Emergency Operating Procedures (Draf t)
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.0 POP 05-E0-E020. " Faulted Steam Generator Isolation," Revision 0
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~ OPOP05-E0eEC21, " Uncontrolled Depressurization of All Steam Generators,"
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Revision 0 OPOP05-E0-ES13, " Transfer to Cold Leg Recirculation," Revision 0 Off-Normal Procedures
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OPOP04-EE-0001, "Statiten Blackout Class IE Battery Capacity," Revision 1 (August 3,1989)
OPOP04-EE-0002, " Loss of 120V AC-Class IE Vital Bus,' Revision 0 (October 12, 1989)
OPOP04-FC-0002,"RefuelingLOCA," Revision 0(December 15,1989)
t OPOP04-TM-0001,"TurbineLoadRejection," Revision 0(FCR-89-1727)
OPOP04-RS-0002, " Malfunction of Rod Control," Revision 0 (FCR 89-1739)
OPOPO4-RP-0003, " Failure of RCS Loop Flow Transmitter," Revision 0 (August 17,.
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OPOP04-RP-0004, " Failure of RCS Loop RTD."rotection Channel," Revision 0 (August 17,1989)
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OPOP04-TM-0004(PT505/506),"" Failure of a Turbine Impulse Pressure-
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Transmitter Revision 0 (August 17,1039)
. 0POPO4-RP-0002, " Loss of Automatic Pressurizer Level r.ontrol," Revision 0 (FCR89-1724, dated September 30,1989)
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-Operating Procedure 1(2) POP 02-AF-0001, " Auxiliary Feedwater." Revision 10(3)
- Administrative Procedures
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OPOP01-ZA-0007, " Plant Operations Procedure Writer's Guide," Revision 3 OPOP01-ZA-0016,'" Emergency Operatins Procedure Writer's Guide," Revision 1
. -3 Field Change Requ.est Forms - 900015,90-0112,and90-0593)
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10 POP 01-ZA-0017, " Emergency Operating Procedure Revision and implementation,"
Rev.ision 2
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0 POP 01-ZA-0018, " Emergency Operating Procedure User's Guide," Revision 0
(February 12,1990) and Revision 1 (May 22, 1990)
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