IR 05000498/1993030

Insp Repts 50-498/93-30 & 50-499/93-30 on Stated Date. Violations Noted.Major Areas Inspected:Plant Status,Onsite Followup of Events,Operational Safety Verification, Maintenance & Surveillance Observations

ML20059C837
Person / Time
Site:	South Texas
Issue date:	10/27/1993
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059C786	List: IR 05000498/1993030 ML20059C782 ML20059C820
References
50-498-93-30, 50-499-93-30, NUDOCS 9311020032
Download: ML20059C837 (22)

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APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV ,

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inspection Report: 50-498/93-30 50-499/93-30 Operating License: NPF-76 NPF-80

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.- 4 Licensee: Houston Lighting & Power Company (HL&P) ,

P.O. Box 1700 Houston, Texas 77251 f

Facility Name: South Texas Project Electric Generating Station, Units I and 2

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Inspection At: Matagorda County, Texas Inspection Conducted: August 14 through September 25, 1993 Inspectors: D. P. Loveless, Senior Resident Inspector J. M. Keeton, Resident Inspector D. M. Garcia, Resident Inspector W. D. Johnson, Chief, Project Section A

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Approved: /243 N % /0/.17/t? 3 Date

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W.D,f/hnson, Chief,ProjectSectionA

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Inspection Summary r Areas Inspected (Units 1 and 2): Routine, unannounced inspection of plant' ,

status, onsite followup of events, operational safety. verification, maintenance and surveillance observations. employee concerns program, licensee -

event report followup, and followup on an unresolved ite Results (Units 1 and 2): ,

i e A valid failure of Standby Diesel Generator 11 was caused by a preposition circuit board failure (Section 2.1). -

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• During this inspection period, the licensee performed steam generator tube inspections on Units 1 and 2. A very small number. of tebes in both l

units were identified as requiring plugging. One tube in Unit 1 l I

appeared to have degraded at a greater rate than anticipated. A review of records showed that the tube had a 59 percent through-wall-indication ;

when tested in 1985 and was not plugged or reported as required I (Section 2.2).

9311020032 931027 l-PDR ADOCK 05000498 )

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• The inspectors observed routine daily work practices in the control room l and at the work sites throughout the plant. Good work practices and j adherence to procedures were observed in most cases. However, specific 4 examples of failure to follow procedures are discussed in other sections l

(Section 3.1).

• During plant tours, the inspectors observed several equipment '

deficiencies which had not been identified on service requests (Section 3.2).

• One noncited violation was documented because a heating, ventilation, and air-conditioning (HVAC) boundary at the essential cooling water intake structure was found breached. No breach permit had been issued for the breach (Section 3.2.1). -

• Excessive failures of the refueling machine caused a delay of the off-load of the Unit I core. The licensee's corrective actions will be  ;

tracked (Section 3.2.3). ,

• One violation was identified involving the failure to perform an engineering evaluation prior to installation of an alternate replacement part (Section 3.4).

• Standby Diesel Generator 23 was inoperable for an extended period of 6

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time because during the maintenance outage, the reverse power relay had not been properly modified prior to installation. This occurred as a result of inadequate procedures and errors in human performance ,

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(Section 3.4). .

• Scheduled maintenance activities on Essential Chiller 11A were performed .

in an acceptable manner. The on-the-job training process was observed as being good (Section 4.1).

• Portions of maintenance on the electrical auxiliary building air handling unit fan were observed. While verifying the equipment clearance order the inspectors discovered that the clearance had not

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been accepted by the mechanics performing the job. One noncited violation was documented (Section 4.2). .

• Postmaintenance test surveillances of the Standby Diesel Generator 11 were observe Problems with alarms, speed, and voltage indications *

were observe The failure of the voltage regulator to increase to the proper voltage was considered a valid failure (Section 5.1).

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• The inspectors reviewed characteristics of the licensee's employee concerns program (Section 8). .

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Summary of Inspection Findings:

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• Inspection Followup Item 498/93030-1 was opened (Section 3.2.3).

• Violation 499/93030-2 was opened (Section 3.4).

• Inspection Followup Item 498/93030-3 was opened (Section 5.1). .

• Licensee Event Report 498/92-007 was closed (Section 6).

• Unresolved Item 499/93015-3 was closed (Section 7).

• Two noncited violations were identified (Sections 3.2.1 and 4.2).

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Attachments:

• Attachment 1 - Persons Contacted and Exit Meeting

• Attachment 2 - Employee Concerns Program

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s-4-DETAILS 1 PLANT STATUS 1.1 Unit 1 Plant Status ,

At the beginning of this inspection period, Unit I was in cold shutdown. On August 17, 1993, the unit entered Mode 6 in preparation for off-loading the fuel from the core to the spent fuel pool. This was considered by the licensee to be the most conservative and effective way to complete the outage on Unit 1, while accommodating steam generator tube inspections.

On August 22, 1993, core off-loading was commenced. . Problems were encountered with operation of the fuel handling machine (refer to Section 3.2.3). Core off-load was competed an September 6. On September 14, steam generator tube-inspection was commenced on all four steam generators.

At the end of the inspection period, Unit I was in Day 233 of the forced maintenance outag .2 Unit 2 Plant Status During this inspection period, the Unit 2 reactor remained shutdown and defueled. At the end of the inspection period, Unit 2 was in Day 210 of the refueling outag .3 Organizational Changes During the inspection period, numerous management changes were made by the licensee as part of their ongoing improvement efforts. The initial phase of _

unitization was implemented on September 14, 1993, with the establishment of separate Unit 1 and Unit 2 Plant Managers, Unit I and Unit 2 Operations Managers, and the Operations Support Manage The second phase.was implemented on September 27, 1993, with the establishment of the Unit I and Unit 2 Maintenance Department and Division Managers, the Maintenance Support Manager, and the Unit 1 and Unit 2 Work Control Manager ONSITE FOLLOWUP OF EVENTS (93702)

2.1 Failure of Standby Diesel Generator (SDG) 11 On September 19, 1993, SDG 11 was started for surveillance testing in accordance with the Plant Surveillance Procedure OPSP03-DG-0001, Revision 0,

" Standby Diesel 11(21) Operability Test." The engine attained rated speed, but voltage only increased to 2900 volts and did not attain the required level of 4160 volts. The SDG was shut down and Service Request 314840 and Station Problem Report 932743 were issued. The preposition circuit board was later found to have failed. This event was considered by the licensee to be a valid

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. l-5-failure of the SDG. The SDG would not have performed its intended safety function had it been necessary. The circuit board was replaced and the SDG 24-hour surveillance test was completed satisfactorily. Daily emergency starts of the machine have been executed following the return of the SDG to an operable status to assess its continued operability. This and other SDG reliability problems will be reviewed in a scheduled NRC inspection of SDG reliabilit ,

2.2 Previous Degradation of a Steam Generator Tube Identified On September 21, 1993, during an inspection of tube integrity in Unit 1 Steam Generator A, the licensee's contractor identified a tube which exhibited degradation in excess of any identified in previous tubes. As a result, the contractor reviewed the historical prestartup eddy-current test data taken on October 5, 1985, which_was the only previous' test occurrence. On further review, this data indicated that in 1985 the tube in question had a 59 percent

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through-wall indicatio Technical Specification 4.4.5 required that the licensee report identified degradation greater than 40 percent through-wall. Because the degradation had not been reported in 1985, on Septcmber 22, 1993, the shift supervisor made a 4-hour nonemergency report of the condition prohibited by Technical Specifications. At the end of the inspection period, the unit was shut down for an extended maintenance outage, and steam generator inspection and tube >

plugging was on-going. The inspectors will further review this event upon issuance of the licensee's 30-day repor :

3 OPERATIONAL SAFETY VERIFICATION (71707) i The objectives of this inspection were to ensure that this facility was being ;

'perated safely and in conformance with license and regulatory requirements, and to ensure that the licensee's management controls were effectively  !

discharging the licensee's rasponsibilities for safe operation. The following l

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paragraphs provide details of specific inspector observations during this inspection perio i 3.1 Control Room Obst ati +

Throughout this inspection period, the inspectors observed control room !

activities on a daily basis. Shift turnovers were of good quality and i

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included a complete review of control panel statu i The inspectors routinely noted increased supervisory activities performed by .;

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the shift supervisor. The control room command and control function was performed with a continued presence of the shift supervisor. The inspectors i discussed the work load with control room personnel. The operators indicated i that_the work control group was relieving a portion of their administrative ,

burden. However, the work control group does not routinely perform work start

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activities on the weekends. The operators stated that on weekend mornings they still have large amounts of administrative work tc support maintenance activities.

The inspectors observed a number of prejob briefings performed in the control roo Two-way communications were noted. This indicates an improvement over-the top-down direction previously noted. Workers were questioning the test '

director to ensure that they fully understood the testing sequence.

The inspectors observed proper use of procedures in the control room. Sel f-checking was evident prior to control board manipulations. Annunciator response procedures were utilized as necessary.

3.2 Plant Tours ,

Throughout this inspection period, the inspectors made routine plant tours.

The inspectors observed a number of equipment deficiencies that had not been identified on service requests. The following are some examples:

• An expansion joint in the essential cooling water supply to SDG 11 was bowed because of interference with structural member * Essential Chillers llA and 12A had dirt, insulation, and pieces of wire in the control cabinets. Also, two oil leaks were noted on the chiller . The component cooling water system had several minor discrepancies including: a damaged temperature element sensing line, loose instrumentation, a hanger lock nut missing and loose conduit connector * Auxiliary Feedwater Pump 13 had a. removed pressure transmitter, and the service lines were not covered for cleanliness contro ,

t On several occasions, the inspectors noted that fire watches would enter a room only long enough to document the entry with the key code reader. This provided insufficient time for more than a minimum observation of the are The observations were turned over to plant managemen .

During routine tours on the backshift, the inspectors held discussions with '

plant workers in the field. The craftsmen indicated that although quality assurance surveillance inspections were performed during the day, there was a !

distinct lack of quality assurance inspectors in the plant at nigh The !

inspectors discussed this feedback with plant management. Quality assurance management -stated that a backshift schedule would be developed to ensure that the surveillance program was taking a representative sample for observation l l

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-7-3. HVAC Boundary Breach On September 21, 1993, during a tour of the esscatial cooling water (ECW)

in ake structure, the inspector observed that Unit 1, ECW Door 14 was obstructed ia the open position with hoses running through the opening. Door 14 was a HVAC boundary door controlled by Plant General Procedure OPGP03-HZ-0001, Revision 0, " Breaching of HVAC Boundtries," which required a permit to allow the HVAC boundary to be breached. The door did not '

have a permit posted and the inspector verified that a permit had not been obtained prior to the breac Prior to the breach, the ECW A train sump pump had seized and a temporary sump pump was needed to pump down the room sum Plant operators had installed the temporary pump by running both a discharge hose and an air supply hose through Door 14. Procedure OPGP03-HZ-0001 states that an approved form shall be required prior to blocking open any HVAC boundary door listed in Addendum Addendum I lists Door 14 as a specific door that is critical to HVAC envelope integrity. The label on the door identifies the door as a HVAC boundary door; however, the label references Plant General Procedure OPGP03-ZF-0003, Revision 6, " Breaching of Fire Doors," as opposed to Procedure OPGP03-HZ-000 The ECW Train A was out of service for a train outage. Therefore, no further action was required for operabilit The licensee took immediate corrective actions by: (1) removing the hoses and obtaining a permit to allow the door to be breached, (2) initiating a station problem report, and (3) writing a plant training bulletin to address boundary breaches. This bulletin was incorporated into the night orders log for operation The licensee proposed the following longer-term corrective actions to prevent recurrence: (1) evaluate sump pump reliability, (2) field change Procedure OPGP03-HZ-0001 to require tne permit to be attached to the door, and (3) apply new labels to reflect the correct HVAC boundary procedure (Procedure OPGP03-HZ-0001) on the applicable door The failure to follow Step 3.3 in this procedure was a violation of Technical Specification 6.8.1.a. However, this violation will not be cited because the licensee's efforts in correcting the violation met the criteria specified in Section Vll.B.(1) of the enforcement polic . Unit 1 Reactor Vessel Head Lift On September 21, 1993, the inspector observed portions of the repair work being done on the Unit I reactor vessel flange 0-ring seating surface. During a previous inspection of tha flange and o-ring seal, a steam cut (maximum depth .001 inches) was fcuna on the reactor vessel flange seating surfac The inspector verified that the personnel performing the repair work were in compliance with the radiati work permit. The hoist operator was cautious while lif ting the head al,) < ,od communications by the maintenance personnel were note ,y

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-8-i 3. Refueling Machine Problems On August 23, 1993, following the transfer of two fuel assemblies to the spent fuel pool, operators attempting to lift a fuel assembly noticed that the assembly was being inserted instead of withdrawn. Station Problem ,

Report 932530 was written to document and correct the problem. The licensee technicians initially determined that the two operating electronic cards were '

defective. After repairs to the cards, the electrical technicians installed ,

the rcpaired cards back in the refueling machine and extensive postmaintenance testing was successfully performe Licensed operators recommenced fuel movement on August 28, 199 After off-loading two fuel bundles, the refueling machine again faile The machine exhibited excessive surgin During the licensee's investigation, several design deficiencies were foun Additional problems with the electronics and the refueling machine hardware were identified and correcte Following a number of problems with the refueling machine, the licensee ,

completed the off-load of the core. The inspectors will review the licensee's corrective actions and the operability of the refueling machine during a future inspection. This item will be tracked as an inspection followup item (IFI 498/93030-1).

3.3 Security Observations During routine activities, the inspectors observed the security force in its day-to-day operations. Searcnes of packages and personnel were of good quality and professionally handled. This indicated an improvement over the previous inspection perio i

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On September 15, 1993, the licensee's contract security force supervisors installed a locking device on the door leading to their offices. This door also provided access to the NRC resident inspector's office. The inspector e discussed this matter with the Vice President, Generation, who agreed that the

' locking device would be remove The door was unlocked and opened immediatel l The inspectors reminded licensee management, that, by law, plant workers could have access to the NRC at all times. Management agreed that locking the outer door would inhibit or discourage plant workers from entering the NRC offices, ,

e and that this was an unacceptable conditio ' SDG 23 Reverse Power Relay Wirina Error As documented in NRC Inspection Report 50-498;499/93-24, the licensee had performed an 18-month maintenance outage on SDG 23, and postmaintenance testing had been in progress. During this inspection period, the inspectors

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t continued to observe and evaluate the testing of SDG 23. On August 21, 1993, following a satisfactory postmaintenance test, SDG 23 was declared operabl t One issue of concern was the improperly modified reverse power relay. The reverse power relay had been replaced as part of the 18-month maintenance outage. Following an unanticipated reverse power trip of the diesel, investigations revealed that the reverse power relay internal wiring had '

differences in polarity in the voltage coil between the originally installed ,

relay and its vendor approved replacement. The original relay had been modified to the nonstandard phase rotation (C-8-A) that was utilized in the HL&P distribution system. This modification was noted as ";pecial" in the instruction manual, with no amplifying remarks to denote the difference in phase rotatio During an attempt to improve the spare parts availability in the warehouse in June 1989, the original reverse power relay model was found to be no longer available. A letter from the SDG vendor recommended a substitute relay that'

required modification prior to installatio Document Change Notice (DCN) JM-178 was initiated to procure the replacement rela DCN JM-178 required an ECNP/ MOD prior to installation and an engineering ,

notification following installation. This requirement was documented by

marking the designated "yes" blocks in the change description block of the DC Replacement components requiring an ECNP/ MOD prior to installation were

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identified using an ECNP/ MOD hold tag. According to Interdepartmental Procedure IP-6.lQ, Revision 12, " Control of Material," the nuclear purchasing ,

and materials management organization (NPMM) was responsible for affixing ECNP/ MOD hold tags and/or engineering notification required tags to replacement parts when required by a procurement documen On September 6,1990, Deficiency Report 90-032 was issued that identified four DCNs (randomly selected from DCNs requiring ECNP/ MOD hold tags) without hold tags found in the warehouse stored items. No document review sheets identifying the ECNP/M0D hold tagging requirements were found with the i procurement documents of the four DCNs. DCN JM-178 was one of the four randomly selected DCNs. As part of the corrective action, measures were l provided to ensure that receipt and warehouse personnel understood the

ECNP/ MOD hold tag and engineering notification tag requirements and restrictions. NPMM performed a search on all DCNs that required tags and verified that the items stored in the warehouse had the appropriate tag .

On November 20, 1992, Station Problem Report 921346 was issued' identifying- !

7 out of 17 warehouse storage bins that did not have the required tags affixed l to the material / equipment. This was found during a quality assurance audi !

As part of the corrective actions NPMM identified all the parts which required ;

tags and placed them on restricted issue by a note attached to the bin. This i restriction required warehouse personnel to verify that the tags were attached prior to issuanc On June 1, 1993, a replacement reverse power relay was requested from the warehouse. On or about' June 7, 1993, this replacement relay was installed in

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-10-SDG 2 This resulted in two reverse power trips on SDG 23 during postmaintenance testing. Apparently, the replacement relay ECNP/ MOD hold tag was not understood by the technician. As a result, maintenance personnel, af ter installing the alternate relay, failed to complete the engineering notification tag and return it to the maintenance engineering departmen The lack of an engineering notification required tag resulted in the alternate relay being installed in SDG 23 without updating the engineering databases '

and/or documents.

Interdepartmental Procedure IP-6.lQ, Revision 12, " Control of Material,"

Section 5.1.10, states, in part, that "The user organization is responsible for complying with Engineering Notification Required tag (s)." The problem with the licensee's tagging program had been identified by different methods, yet it was still apparent that the requirements for tagging the material with the appropriate tag to maintain configuration control and ensuring that the end user return the tag to the maintenance engineering department were not sufficient measures to ensure that an ECNP/ MOD package was developed prior to installation or that engineering personnel were notified following installation.

Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained including the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Item 9.a of Appendix A states, in part, " Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances." A note to Step 6.9.2.A of Operations Engineering Procedure OEP 6.03Q, Revision 7,

" Design Document Change Control," implements this requirement for modification work and states that, " Items tagged with ECNP/ MOD Hold tag shall not be installed until a ECNP/ MOD is issued authorizing the use of a given part."

On or about June 7,1993, maintenance personnel installed an alternative reverse power relay that had an ECNP/ MOD hold tag attached, without an ECNP/MC7 package being issued authorizing its use. This constituted a violation of Technical Specification 6.8.1.a (VIO 499/93030-2).

The inspector reviewed several procedures associated with the licensee's modification proces Procedure OEP 6.03Q governed the purchasing of the replacement reverse power relays. Although this procedure could be used to perform a minor modification, the procedure required that an ECNP/ MOD package be developed. Interdepartmental Procedure IP-3.24Q, Revision 6, " Engineering Change Notice Package," states that an ECNP may be authorized by a design change request in accordance with Interdepartmental Procedure IP-3.01Q, " Plant Modifications." Upon review, the inspector determined that Procedure IP-3,01Q had been superseded in its entirety by Plant General Procedure OPGP04-ZE-0310,

" Plant Modifications."

In addition to this array of procedures, the inspectors found that several portions of the procedures did not clearly require appropriatt action t s c

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-11-Several processes could be used to facilitate the same change. Workers receiving parts with ECNP/ MOD tags had to know which procedure to look in.to find the requirements before proceeding. These requirements may be obscure notations in the responsibility section or nonexisten The licensee informed the inspectors that the program would be revised to provide for a single path for a given type of modification. The procedures '

are to be revised to better reflect the specific program requirements. ' Al so ,-

licensee management stated that the responsibility for obtaining an engineering evaluation of replacement parts would no longer be left to the craftsma The inspectors noted one barrier that could have prevented this violation. On May 28, 1993, during the maintenance outage, the original reverse power rela had been removed and bench tested by an electrical technician using Department Procedure OPMP05-ZE-0015, Revision 2, " Calibration of G.E. Type ICW Relays."

The procedure specifically instructed the technician on the method of test setup, which accounted for the polarity of the relay. The technician began the test but, when the relay did not respond as expected, he reversed.the relay test leads to obtain proper actuation and continued with the tes Therefore, the technician failed to identify that the relay was wired with an opposite polarity The results of the test then erroneously indicated satisfactor However, the decision was made to replace the relay based on the appearance of heat damage to the rela On June 1, 1993, the replacement relay was bench tested using the same procedure mentioned above and was considered satisfactory. However, had the test of the original relay identified the inverted polarity, technicians should have identified the difference in the new relay. When questioned on the standard practice when problems arise while performing a test, the electrical crew leader stated that there was a " maintenance feedback request" <

form that should be filled out by a technician when a question or concern about a procedure was identified. This form should have initiated a field change request that would have been incorporated into the procedure. The electrical technician did not fill out this form because he felt that the test was performed satisfactory, although he had to reverse the test plug lead The failure to utilize appropriate work practices on the troubleshooting of the original relay resulted in the failure to identify an inverted polarity in its replacemen .5 Conclusions The inspectors identified continuing problems with the licensee's system for procurement, warehousing, and tagging of alternate replacement component Also, several examples of personnel failing to adhere to procedures were identified. Some improvement was noted in control room command and contro Inspectors continue to identify equipment deficiencies that have not been identified on service requests. The implementation of the work control group appears to be progressing, but some difficulties still exis .

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-12-4 MONTHLY MAINTENANCE OBSERVATIONS (62703)

The inspectors observed station maintenance activities and reviewed documentation to ascertain that the activities were conducted in accordance with the licensee's approved maintenance programs, the Technical Specifications, and NRC regulations. The inspector verified that the I activities were conducted in accordance with approved work instructions and procedures, the test equipment was within the current' calibration cycles, and ,

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housekeeping was being conducted in an acceptable manne Activities witnessed included work in progress, post maintenance test runs, and field walkdown of the completed activities. Additionally, the work packages v;re reviewed and individuals involved with the work were' interviewed. All observations made were referred to the licensee for appropriate actio .1 Scheduled Preventive Maintenance of Essential Chiller llA (Unit 1)

On August 31, 1993, the inspector observed scheduled maintenance on Essential Chiller llA. The work was performed in accordance with Plant Maintenance Procedure OPMP05-CH-0001, Revision 5, " York Chiller Inspection & Maintenance 150 to 550 Tons." The procedure and work package provided necessary guidance for the workers to perform the required maintenance. All approvals and clearances were in place as_ required. Because Unit I was shutdown and defueled, minimal Technical Specification impact was involved; however, with the chiller out of service more than 7 days, the control room HVAC Trains and C were required to be placed in emergency recirculation in accordance with~

Technical Specification 3.7. The preventive maintenance evolution was being used as a training device to certify additional HL&P employees on the York brand chillers. The inspector observed the on-the-job training being provided by the York contractors. The inspector also reviewed the list of HL&P employees certified to do the task as 4

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well as a list of certified vendors. All instruction and evaluation was conducted in a professional manne On September 1, 1993, the shift supervisor took the Technical Specification 3.7.7 required action and placed Trains B and C of the control room HVAC in the recirculation mode prior to exceeding the 7-day allowed ,

outage time in the action statemen On Septe >er 15, 1993, the inspector conducted a walkdown on Essential Chiller 11A during the postmaintenance test following a static fill:and ven All parts obsurvable that were replaced during the maintenance were verified to be the correct parts. One filter connection was found to be seeping oil ,

and was identified to the mechanic who promptly took the necessary corrective !

actio ,

Following the postmaintenance test runs, the system was returned to service and the inspector reviewed a copy of the completed maintenance package. All required signatures and quality control inspections were in the closure package along with the completed data sheet l

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-13-4.2 Electrical Auxiliary Building Main Air Handling Unit Supply Fan llA On September 17, 1993, the inspectors observed portions of maintenance to the electrical auxiliary building main air handling unit Supply. Fan ll Service Request HE-1-179301 was written to replace the fan rotors to correct unacceptable vibration. A runout was performed on both ends of the shaft as directed by the work instructions. The inspector verified that both shaft '

readings were acceptable, and the dial indicator utilized was within calibration. The inspector verified that the replacement parts were certified for the application. The quality control hold points were met and were appropriate. Mechanical maintenance personnel performed the tasks according to the work package documented under Work Authorization 92040423 and kept the work area clea While verifying that the equipment clearance order (ECO) was appropriate, the inspector noted that the EC0 number that was documented in the work package had been released on September 14, 1993. The inspector questioned the work'

control operator. The ECO had been released to electrical maintenance personnel in order to perform an uncoupled run on the motor, as directed by ,

the work package, and a new EC0 had been issued. The new ECO, however, had not been accepted by the mechanical maintenance personnel prior to performing maintenance on the fa ,

Procedure OPGP03-ZO-0039, Revision 4, " Operations Configuration Management,"

states, in part, "A single work document may require support from other than the lead craft, in this instance, each craft SHALL accept the ECO separately for that document." A station problem report (SPR 932766) was writte Although considered a failure to follow procedures, this violation was not cited because it met the criteria specified in Section VII.B.(1) of the j enforcement polic ;

As directed by plant management, a maintenance " stand down" was initiated to ,

brief personnel on the safety significance of obtaining an appropriate EC The stand down was in effect for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and included both Units 1 and .3 Conclusions ,

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Maintenance on the essential chillers was in accordance with approved procedures and work packages. The on-the-job training program appeared to be working well for chiller technicians. Quality control practice was goo i Failure of workers to have the proper equipment clearance order in place j

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before starting work resulted in a general stand down from all work while training took place. While it appeared that some progress-had been made in improving work practices, isolated examples of improper work were still observe BIMONTHLY SURVEILLANCE OBSERVATIONS (61726)

The inspectors observed the following surveillance testing of a safety-related component to verify that the activities were being performed in accordance with the licensee's approved programs and the Technical Specification .1 Postmaintenance Testing of SDG 11

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On September 13, 1993, the inspector observed the initial 15-minute postmaintenance test run. The SDG was started in accordance with the appropriate procedures. The initial start was uneventful and the SDG responded as expected. Following the initial run, the SDG was secured and then restarted and run in the emergency mode to allow trip testing of the nonemergency trip signals without tripping the SDG. During the testing of the low lubricating oil pressure trips, unexpected alarms were received. When the SDG was released from emergency and placed in cooldown, the SDG tripped T.nd simultaneous low starting air pressure and sequencer malfunction alarms were, received. Testing was suspeded until a cause for the alarms and indications could be determine On September 14, 1993, another run was conducted to determine if the alarms and alarm sequence were repeatatle. Also, it was determined that a diesel trip (instead of entering the cooldown cycle) should have been expecte Because any actuation of the trip relays that were being tested would defeat the cooldown permissive, the SDG tripped when it was released from the emergency mode. The same alarms and alarm sequence were determined to be repeatable. Further runs were delayed until the problem could be better understoo On September 16, 1993, another SDG 11 run was initiated to complete the postmaintenance testing and perform a 24-hour surveillance run. The same alarms that occurred during the previous run repeated, but the alarms were ,

explained by the engineer using the logic diagrams. The alarms apparently occurred as a result of design flaws introduced during a modification (ECNP-89-J-0043). When the SDG was started, the speed indication in the >

control room was erratic and oscillated between 600 and 650 RPM. The voltage and frequency indicated correctly and was steady. Local indications and engine noise indicated that the SDG was operating steadily at the correct speed. Investigation revealed a plug (amphenol) on the tachometer was broke The SDG was shutdown to replace the plug and continue alarm investigatio On September 19, 1993, SDG 11 was started for surveillance. The engine start was acceptable, but the voltage failed to increase to the required value. The voltage only reached 2900 volts instead of 4160 volts. The SDG was shutdown and a station problem report written. Investigation revealed the preposition circuit boards in the control panel exhibited heat degradation. This resulted in loose components and poor electrical contact on the circuit board. The'

boards were replaced and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run was completed without i

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-15-The licensee's corrective actions in response to the apparent design flaw and !

the circuit board failure will be reviewed during a future inspection (IFl 498/93030-03).

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5.2 Conclusions Even though a number of random problems occurred during the post-maintenance ~

test on SDG 11, the starting and run evolutions were well managed and controlled. Pre-job briefings, assignment of specific duties, and general '

expectations were provided to the operators prior to all surveillance observe ONSITE REVIEW OF LICENSEE EVENT REPORTS (92700)

(Closed) Licensee Event Report 498/92-007: Unplanned Engineered Safety Features Actuation of the Fuel Handling Building HVAC System 1 The licensee reported an unplanned actuation of the fuel handling building-HVAC that was caused by lack of attention to detail by an Instrumentation '

and Control technician. The technician entered a value of 1.52E-3 versus l.52E+3 into the RM-23A module. The erroneous value was processed and caused an engineered safety features actuation of the HVAC. The corrective actions included a written reminder to the Instrumentation & Control technician that ,

self-verification was required and an evaluation of procedures that needed to +

be revised to identify steps that required dual verificatio The procedures which contained steps requiring entering system trip setpoints were revised to require dual verification by the technician and to include a note to remind the technician of the requirement. The procedures revised were:

a OPSP14-RA-1001, "RCB Purge Isolation Monitor (AIRA-RT-8012 or A2RA-RT-8012) Calibration"

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• OPSP14-RA-1009, "RCB Purge Isolation Monitor (CIRA-RT-8013 or C2RA-RT-8013)" ,

• OPSP14-RA-1004, " Control Rm/ Aux Building Vent Monitor (AIRA-RT-8033 or A2RA-RT-8033) Calibration" ,

• OPSP14-RA-1012, " Control Rm/ Aux Building Vent Monitor (CIRA-RT-8034 or l

C2RA-Rl-8034) Calibration"

• OPSP14-RA-1005, " Spent Fuel Pool Exhaust Monitor (AIRA-RT-8035 or A2RA-RT-8035) Calibration" ,

• OSP14-RA-1013 " Spent fuel Pool Exhaust Monitor (ClRA-RT-8036 or -

C2RA-RT-8036) Calibration" {

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• IPOP02-HC-0003, " Supplementary Containment Purge," Revision 1

+ 2P0P02-HC-0003, "Supplementory Containment Purge," Revision 1

• OPSP02-RA-8012 "RCB Purge Airborne Monitor DCOT (RT-8012)," Revision 2

= OPSP02-RA-8013, "RCB Purge Airborne Monitor DCOT (RT-8013)," Revision 2 ,

• OPSP02-RA-8033, " Control Room / Aux Building Vent Monitor DCOT (RT-8033),"

Revision 1

• OPSP02-RA-8034, " Control Room / Aux Building Vent Monitor DCOT (RT-8034)," .

Revision 1

• OPSP02-RA-8035, " Spent Fuel Pool Exhaust Monitor DCOT (RT-8035),"

Revision 2

• OPSP02-RA-8036, " Spent Fuel Pool Exhaust Monitor DCOT (RT-8036),"

Revision 2 The inspector reviewed the licensee's procedures and verified that revisions to the identified procedures had been made.

7 FOLLOWUP ON AN UNRESOLVED ITEM (92702)

(Closed) Unresolved Item 499/9315-03: High Differential Pressure In SDG 23 ;

Fuel Oil Strainer

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As documented in NRC Inspection Report 50-499/93-15, SDG 23 had received a high differential pressure indication across the duplex fuel oil strainer.

The high differential pressure was caused by an instrumentation problem. A

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faulty pulsation dampener created a false low indication on the downstream side of the strainer, thus creating an apparent high differential pressure drop across the strainer.

Foreign material discovered in the strainer was determined to be iron oxides and rust. The specific origin was unknown, but speculated to have come from either the fuel oil storage tank or the pipe wal The quantity of the material found was insignificant and it was the design intent of the strainer to filter such particles.

The licensee initially classified this event as a valid failure, but later determined that the operability of the diesel' generator had not been affected based on the results of the investigation. The inspector reviewed the licensee's evaluation and agreed with the licensee's determination'.

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-17-8 EMPLOYEE CONCERNS PROGRAM (2500/028)

The inspector reviewed the licensee's employee concerns program, called the SPEAK 0VT program. The inspector interviewed the manager of quality performance / SPEAK 00T and reviewed site procedures to collect the information required by Temporary Instruction 2500/028. Information about the SPEAK 00T program is summarized in Attachment 2. The following procedures were ,

reviewed: ,

Number Revision Title SPI-01 1 Interview Procees SPI-02 3 Classification of Concerns SPI-03 3 Class 1 Concern Investigation Process SPI-04 3 Class 2, 3, 4, and 5 Concern Process SPI-05 2 Response Letter Process .

SPI-06 2 Filing and Tracking Concerns SPI-07 2 Speakout Reports '

SPI-08 2 SPEAK 0VT Review Committee SPI-09 1 Recommendations / Suggestions SPI-10 3 Potential Wrongdoing Investigations SPI-12 2 Review of Class 1 Investigation Reports SPI-13 0 Verification of Concerns At the time of this survey, licensee contractors were starting an independent evaluation of the SPEAK 0VT program. The NRC plans to perform an evaluation of the program in the near futur ;

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ATTACHMENT 1 1 PERSONS CONTACTED Licensee Personnel

• R. Balcom, Director, Nuclear Security

1. D. Bize, Licensing Engineer

1. J. Calloway, Participant Services

• T. Cloninger, Vice President Nuclear Engineering

• W. Cottle, Group Vice President, Nuclear *

• 1. M. Coughlin, Senior Licensing Engineer

• D. Daniels, Administrator, Corrective Action Group

• 1. J. Groth, Vice President, Nuclear Generation

• 1. S. Head, Deputy, General Manager Licensing

• J. Johnson, Supervisor, Quality Assurance

• 1. T. Jordan, General Manager, Nuclear Engineer

• D. Keating, Director, Independent Safety Engineering Group

• W. Kinsey, Vice President, Plant Support

• A. Mikus, Supervisor, Engineering Material Technical Service Nuclear

• 1. L. Myers, Plant Manager, Unit 1

• 1. M. Pacy, Manager, Design Engineering

• G. Parkey, Plant Manager

• 1. P. Parrish, Senior Specialist, Licensing

• R. Pell, Manager, Health Physics

1. R. Rehkugler, Director, Quality Assurance

• K. Richards, Outage Manager (A)

• 5. Rosen, Vice President, Nuclear Engineering

• 1. J. Sheppard, General Manager, Nuclear Licensing ,

• E. Stansel, Division Manager, Plant Engineering Department l K. Taplett, Manager, Quality Derformance/ SPEAK 0VT

1. R. Tennant, Director, Nuclear Purchasing & Materials Management

• T. Underwood, Manager, Maintenance Support

• G. Walker, Manager, Public Information

• 1. K. Wissman, Engineer, Material Technical Service Nuclear

• Denotes personnel that attended the exit meeting conducted on September 28, 1993. # Denotes personnel that attended the exit meeting conducted on October 7. In addition to the personnel listed above, the inspectors contacted other personnel during this inspection perio EXIT MEETING An exit meeting was conducted on September 28, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. An additional exit meeting was conducted on October 7 to discuss the Standby Diesel Generator 2 l reverse power relay which had been installed without being properly modifie The licensee did not identify as proprietary, any information provided to, or ,

reviewed by the inspectors. At the exit meetings, licensee representatives  !

acknowledged the findings and did not express disagreemen l l

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ATTACHMENT 2 EMPLOYEE CONCERNS PROGRAMS PLANT NAME: SOUTH TEXAS PROJECT 11CENSEE: HOUSTON LIGHTING & POWER DOCKET 050-0498; 050-499 NOTE: Please circle yes or no if applicable and add comments in the space ,

provide PROGRAM: Does the licensee, have an employee concerns program?

(Yes or No/ Comments) YE IT IS CALLED SPEAK 0U . Has NRC inspected the program? Report # 91-29 and 92-07 SCOPE: (Circle all that apply) Is it for: Technical? (Yes, No/ Comments) '!ES Administrative? (Yes, No/ Comments) YES Personnel issues? (Yes, No/ Comments) YES . Does it cover safety-as well as non-safety issues?

(Yes or_No/ Comments)

YES, ALL RECEIVED CONCERNS ARE ADDRESSE . Is it designed for: Nuclear safety? (Yes, No/ Comments) YES Personal safety? (Yes, No/ Comments) N0, BUT CONCERNS IN THIS AREA ARE ADDRESSE Personnel issues - including union grievances?

(Yes or_No/ Comments) NO, BUT CONCERNS IN THIS AREA ARE ADDRESSE . Does the program apply to all licensee employees?

(Yes or_No/ Comments) YES Contractors?

(Yes or_No/ Comments) YES Does the licensee require its contractors and their subs to have a similar program?

(Yes o_t No/ Comments) NO  ;

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- 2-- Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?

(Yes at No/ Comments) TERhilNATING EhfPLOYEES ARE OFFERED THE OPPORTUNITY OF AN EXIT INTERVIEW WITH SPEAKOU THEY ARE ALSO GIVEN A CONCERN FORhi WHICH THEY MAY COhfPLETE AND RETURN BY hiAI .

C. INDEPENDENCE: What is the title of the person in charge?

MANAGER, QUALITY PERFORMANCFJSPEAKOUT , Who do they report to?

GENERAL MANAGER NUCLEAR ASSURANCE Are they independent of line management?

YES, REPORTING TO THE GROUP VICE PRESIDENT, NUCLEAR- Does the ECP use third party consultants?

YES, WHEN NEEDED TO HANDLE WORKLOAD OR FOR SENSITIVE CASE . How is a concern about a manager or vice president followed up?

IT WOULD BE REFERRED TO THE NEXT HIGHER MANAGEMENT LEVE D. RESOURCES: What is the size of the staff devoted to this pmgram?

FIVE PLUS THE MANAGER What are ECP staff qualifications (technical training, interviewing training, investigator training, other)? _

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YEAR DEGREE OR 5 YEARS RELATED EXPERIENCE ONE YEAR RELATED EXPERIENCE, PREFERABLY IN OVERSIGHT ORGANIZATION MAINTAIN QUALIFICATION FOR UNESCORTED ACCESS NO FAMILY MEMBERS EMPLOYED AT SITE

< REFERRAIE: Who has followup.on concerns (ECP staff, line management, other)?

NUCLEAR SAFETY OR QUALITY CONCERNS ARE INVESTIGATED BY .

THE SPEAKOUT STAFF. OTHER CONCERNS MAY BE REFERRED TO THE APPROPRIATE ORGANIZATION. THE SPEAKOUT STAFF PROVIDES FOLLOWUP AND FEEDBACK TO THE CONCERNED INDIVIDUA ,

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_3_ CONFIDENTIALITY: Are the reports confidential?

(Yes or No/ Comments) YES Who is the identity of the alleger made known to (senior management, ECP ,

staff, line management, other)? l (Circle, if other explain)

l GENERALLY ONLY THE SPEAKOUT INVESTIGATOR KNOWS THE IDENTITY, IF RESOLUTION OF THE CONCERN REQUIRES THAT l

OTHERS KNOW THE IDENTITY, THE CONSENT OF THE CONCERNED IS OBTAINE .

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' Can employees be: Anonymous? (Yes, No/ Comments) YES Report by phone? (Yes, No/ Comments) YES. IN ADDITION, l CONCERNS MAY BE PLACED IN BOXES IN VARIOUS LOCATION l FEEDBACK:

I 1. Is feedback given to the alleger upon completion of the followup?

(Yes or No - If so, how?) YES, BY LUllhK TO RESIDENC Does program reward good ideas? j NO \ Who, or at what level, makes the final decision of resolution?

i THE GENERAL MANAGER NUCLEAR ASSURANCE APPROVES ALL RESOLUTIONS. A REVIEW COMMirinu REVIEWS RESOLUTIONS OF NUCLEAR SAFETY OR QUALITY CONCERN , Are the resolutions of anonymous concerns disseminated?  !

BULLETIN BOARDS Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?

BULLETIN BOARDS, NEWSLH11tR FOR SOME ITEMS EFFECTIVENESS: How does the licensee measure the effectiveness of the pmgnm?  ;

TRACKS THE NUMBER OF CONCERNS RECEIVED AND THE NUMBER OF OPEN CONCERNS.

4 Are concerns:

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-4- Trended? (Yes or No/ Comments) YES Used? (Yes or No/ Comments) YES, CORRECTIVE ACTIONS ARE TAKEN FOR SUBSTANTIATED CONCERN . In the last three years how many concerns were raised? _687 of the concerns raised, how may were closed? _643 What percentage were

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substantiated? 22% How are followup techniques used to measure effectiveness (random survey, interviews, other)? ,

INTERVIEWS WERE USED IN JANUARY 1993 TO DETERMINE WHETHER EMPLOYEES WERE COMFORTABLE RAISING CONCERNS WITH SUPERVISORS, AND WHERE THE EMPLOYEE WOULD GO FIRST WITH A CONCER . How frequently are intemal audits of the ECP conducted and by whom?

NONE CONDUCTED, BUT AN INDEPENDENT ASSESSMENT COMMENCED IN SEPTEMBER 199 . ADMINISTRATION / TRAINING: Is ECP prescribed by a procedure? (Yes n No/ Comments) YES How are employees, as well as contractors, made aware of this program  ;

(training, newsletter, bulletin board, other),7 GENERAL EMPLOYEE TRAINING AND REQUALIFICATION, POSTERS, NEW EMPLOYEE ORIENTATION TRAINING, AND BULLETIN BOARD POSTING OF CONCERN FINDINGS ADDITIONAL COMMENTS: (Including characteristics which make the program especially effective, if any.) ,

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THE PROGRAM PROVIDES EASY ACCESS, CONFIDENTIALITY, ALLOWS ANONYMOUS CONCERNS, PROVIDES FEEDBACK, AND HAS BEEN USED REGULARLY BY EMPLOYEE NAME: W. D. JOHNSON ,

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TITLE: CHIEF, PROJECT SECTION A, DIVISION OF REACTOR PROJECTS PHONE #: 817-860 8148 DATE COMPLETED. SEIrrEMBER 7,1993 l

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