IR 05000498/1993039
| ML20058F377 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/29/1993 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058F369 | List: |
| References | |
| 50-498-93-39, 50-499-93-39, NUDOCS 9312080091 | |
| Download: ML20058F377 (13) | |
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I APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION I
REGION IV
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Inspection Report:
50-498/93-39 50-499/93-39 l
t Operating Licenses:
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NPF-80 t
Licensee:
Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001
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Facility Name:
South Texas Project, Units 1 and 2 Inspection At:
Bay City, Texas Inspection Conducted:
October 25 through 29, 1993
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Inspector:
T. O. McKernon, lead Inspector, Projects Section A,
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Division of Reactor Projects l
L. E. Ellershaw, Reactor Inspector, Maintenance Section,
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Division.of Reactor Safety
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Approved:
[/A[
//M 9/(/3
m W.D.d6hnson, Chef,ProjectsSectionA,
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Date Division of Reactor Projects
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Inspection Summary j
Areas; Inspected (Units 1 and 2): Routine, announced inspection of l
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postmaintenance testing program (Restart Issue.4 of NRC Inspection Report 50-498/93-31; 50-499/93-31) and related previous inspection findings.
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Results (Units 1 and 2):
The licensee had restructured the postmaintenance testing program. The-
revised program was adequate to address those programmatic weaknesses noted in the related items revir. red during this inspection (Sections l'
and 3).
At the conclusion of this inspection, Restart Issue 4 remained open.
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Evaluation of the postmaintenance testing program will be antinued in a future inspection.
9312080091 931201 PDR ADOCK 05000498-i G
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-2-Summary of Inspection Findings:
IFis 50-498/9331-14 and -68; 50-499/9331-14 and -68 were closed
(Section 3).
IFIs 50-498/9331-13, -51, and -69; 50-499/9331-13, -51, and -69 were
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reviewed and left open (Section 3).
Licer,ser. Event Reports (LERs) 4 8/9204, 9214, and 9216 were closed
(Section 4).
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Violations 50-499/9226-03 and 9320-02 were closed (Section 2).
- Attachments:
Attachment I - Persons Contacted and Exit Meeting
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Attachment 2 - Documents Reviewed
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-3-DETAILS 1 LICENSEE'S EFFECTIVENESS IN IDENTIFYING, PURSUING, AND CORRECTING PROGRAMMATIC PROBLEMS RELATED TO THE POSTMAINTENANCE TESTING (PMT)
PROGRAM (92720)
During the inspection, the licensee's corrective actions related to the restructuring of the PMT program were reviewed to ascertain whether previous concerns identified in NRC Inspection Report 50-498/93-31; 50-499/93-31 had been adequately addressed.
1.1 Background in a number of previous inspections (e.g., Diagnostic Evaluation Team Inspection, and others) weaknesses related to PMT were noted. A number of weaknesses were observed in which surveillances and postmaintenance testing did not always verify equipment operability. A number of exampies were presented such as not performing PMT on a standby diesel generator output breaker after a fuel oil injector pump was repaired. As a result during subsequent surveillance testing, the steam diesel generator output breaker failed to close onto the bus.
In addition, a number of problems could be
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attributed to a poor PMT reference manual.
The licensee committed to resolve PMT-related problems prior to power ascension.
1.2 Licensee's Corrective Action During the inspection, the inspectors reviewed the licensee's corrective actions to resolve problems associated with the PMT program.
The licensee took actions to restructure the PMT program. The base guidance documents were revised. These included the work process program, the PMT program procedure,
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and the PMT reference manual.
Integral in restructuring the PMT program was the segregation of the PMT process from the operability testing process and the creation of the operations work control group (0WCG).
Through the new
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work process, the work planners, using the PMT reference manual, specified the i
required PMT for the associated work activities.
Subsequent review was performed by the 0WCG acting as the work start authority (WSA).
If warranted, and the originating work planner notified, PMT(s) could be waived until performance of the operability test.
The PMT waiver could only be used when the operability test would satisfy the PMT attributes such as satisfying a leakage test on a pump with the in-service testing pump surveillance. The responsibility for tracking the operability test resided with the operations department.
In addition, the licensee incorporated PMT training of maintenance personnel, licensed operators, and others into the required outage training.
1.3 Conclusion The licensee's corrective actions to restructure the PMT program were adequate in addressing the previously identified concerns reviewed in this repor _
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l Additional corrective actions related to PMT are addressed in Section 3 of this report.
2 FOLLOWUP DN CORRECTIVE ACTIONS FOR VIOLATIONS AND DFVIATIONS (92702)
i 2.1 (Closed) Violation 499/9226-03:
Failure to Perform Postmaintenance l
Test on Essential Chiller 21C Breaker
This violation involved the failure to perform PMT on Essential Chiller 21C
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power supply breaker following completion of Service Request (SR) 115415 and
return to service.
Subsequent attempted starting of the chiller failed.
The licensee initiated the following corrective actions:
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Individual SRs were issued to perform inspection and PMT of the
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remaining 4801 breakers referenced in SR 115415.
i A memorandum was issued to operations personnel emphasizing requirements
of Operations Policy 0-0054, " Electrical Breaker Continuity Checks."
The maintenance planner's guide was revised to discuss handling of
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multiple component work packages to ensure that required PMT is performed on the individual components.
i Training was incorporated into the next licensed operator
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requalification training to reinforce lessons learned. Training was
completed by March 1, 1993.
A review of records and documents confirmed that the licensee's corrective
actions had been completed and were adequate to address the concerns of the violation.
2.2 (0 pen) Violation 498/9236-06: 499/9236-06:
Failure to Recuest Relief From ASME Code Reouirements i'
While not a restart-related item, the inspectors reviewed this item because of its relationship to IFI 498/9331-51; 499/9331-51 pertaining to precision
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calibrations of flow instrumentation discussed below. NRC Inspection Report 50-498/92-36; 50-499/92-36 identified that the essential cooling water
flow element installation for the Units 1-and 2 component cooling water (CCW)
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heat exchanger had an error of 7 percent of full scale and no relief from the
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provisions of Section XI of the ASME Code had been requested.
The licensee performed an evaluation and determined that similar instrument inaccuracies existed in the essential chilled water'and safety injection i
systems. An evaluation of data collected during previous ASME Section XI pump testing was conducted and it was concluded that the instrumentation for the three systems provided results capable of detecting pump degradation and,
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therefore, met the intent of the ASME Code. The licensee installed temporary
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flow instruments in the essential chilled water and safety injection systems which are capable of achieving the required ASME Code accuracy (2 percent),
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and which will be used until the existing instrumentation is precision
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calibrated. The applicable reference value procedures, inservice test
procedures, and calibration specificction sheets were revised to reflect usage
of temporary flow instrumentation.
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As described below, the existing instrumentation for the essential cooling
water system in Unit I has been precision calibrated. Unit 2 is scheduled for i
precision calibration during December 1993.
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Corrective actions taken to preclude recurrences of using instrumentation that does not meet accuracy requirements and failing to request relief from ASME Code requirements incicded procedure revisions.
Procedures OPGP03-ZE-0021, i
" Inservice Testing Program for Valves," and OPGP03-ZE-0022, " Inservice Testing
Program for Pumps," were revised on September 14, 1993, under Field
Changes FC93-1400 and FC93-1401, respectively.
The changes required relief l
requests to be submitted to the NRC within 6 months of discovery of the need
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for the request.
The revisions also required that compensatory actions be l
taken until the relief request is granted by the NRC.
Procedure IP-3.04Q, t
" Inservice Inspection Program," was revised (Revision 2) to require the responsible engineer to assure that instrumentation used to collect data for
inservice testing is accurate to within the tolerances specified in Section XI l
of the ASME Code, prior to inclusion of the instrumentation in the testing i
plan.
In addition, Procedure OPGP03-ZE-0031, " Design Change Implementation,"
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was revised (Revision 7) to require consideration of programmatic impact to
the ASME Code Section XI Pump and Valve Testing Program in the event of a
design change to the existing configuration. The design change checklist -
l specifically identified the "+/- 2 percent" instrument accuracy as a potential
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impact to Section XI equipment.
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This item shall remain open until completion of the precision calibrations of l
the installed flow instrumentation in the Unit 2 essential cooling water l'
system, currently scheduled for December 1993.
2.3 (Closed) V olation 50-499/9320-02:
Failure to Incorporate a Field
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Chance into a Procedure Revision
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This violation involved the failure to incorporate a field change (FC-92-0424)
into the next revision of Surveillance Test Procedure 1 PSP 03-SP-0009C, "SSPS i
Actuation Train C Slave Relay Test," Revision 2.
The error resulted in a
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misinterpretation of the procedure and an inadvertent start of Auxiliary
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Feedwater Pump 13.
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The licensee took corrective actions to incorporate Field Change FC93-0980 into Procedure 1 PSP 03-SP-0009C to clarify the action step.
Further, a
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memorandum from the Vice President Nuclear Engineering was distributed to
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nuclear engineering personnel stating the lessons learned from the event and
management's expectations regarding future procedure revisions.
Discussion
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i with key engineering personnel verified that personnel were aware of these management expectations.
At the time of this inspection, a review of the surveillance test procedure and other documentation (Attachment 2) by the inspector verified that the
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licensee's corrective actions had been implemented and were adequate to address the concern of the violation.
3 FOLLOWUP (92701)
3.1 (0 pen) IFl 498/9331-13: 499/9331-13:
PMT Program and implementation Weaknesses
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This IFI involves weaknesses associated with the PMT program and relates to more than one Restart Issue (i.e.; 4, 11, and 12).
This IFI will remain open until other common items (e.g.; IFIs 9331-03, -04,
-07, -10, -15, -51, -63, and -79) have been reviewed and satisfactory basis
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for the closure of the Restart Issue has been established.
3.2 (Closed) IFI 498/9331-14: 499/9331-14:
Inadeouate Postmaintenance Testing Reference Manual i
This IFI involved a concern that the PMT reference manual used by planners to l
select the appropriate test requirements did not specify the appropriate
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detail and occasionally specified the wrong test.
A review of the previous Revision 7 of the PMT reference manual and discussions with key maintenance personnel verified that the prior PPT
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reference manual was cumbersome to use, contained an outdated generic component listing, and used an acronym list for testing which added confusion to the PMT process. As corrective action to resolve the prior PMT reference-
manual problems, the licensee upgraded the PMT reference manual, Revision 8, to restructure the manual (Attachment 2). The new revision of the manual
included PMT planning guidance for the maintet.ance planners to ascertain which
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PMTs were required based upon the discipline work activity (e.g.; welding) and used a PMT cross-reference matrix to select appropriate testing attributes.
The upgraded PMT reference manual had been developed from reviews of other
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facilities' PMT programs and current industry guidance.
Further, the PMT reference manual segregated all PMT testing requirements from any operability i
tests performed to verify that the systems, structures'or components affected
by the corrective maintenance were capable of performing their intended and speci.*ied design. functions.
A review of the PMT reference manual noted that the manual appeared to be better structured and less confusing than the prior
manual revision. Discussions with maintenance department personnel confirmed this observation.
In addition to the above, the inspectors reviewed PMT training given to
licensed operators during the requalification cycle (Course LOT 504.01). The training appeared to be comprehensive and well presented to the trainees.
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l 3.3 (0 pen) IFI 498/9331-51: 499/9331-51:
Performance of Precision
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Calibrations on Installed Flow Instrumentation to Preclude the use of Temporary Flow Instrumentation The licensee, in Part D of Section III in the Operational Readiness Plcn, I
committed to perform, prior to the resumption of power operations, precision calibrations on the installed flow instruments in the CCW heat exchanger
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outlet to the essential cooling water system to preclude having to use
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temporary flow instruments.
At the time of this inspection, the licensee had completed precision calibrations on the Unit I flow instrumentation in the CCW heat exchanger outlet to the essential cooling water system.
The inspectors verified, by
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review of applicable documentation, that the calibrations had been performed.
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Service Requests 176271, 176272, and 176273, each dated June 23, 1993,
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initiated the actions required to perform the calibrations on the flow indicators and flow transmitters in trains A, B, and C, of Unit 1.
The instrumentation for Trains A, B, and C, was calibrated and returned to service
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on September 1, October 11, and July 13, 1993, respectively.
Each of the i
three work packages contained the completed (signed off and dated) work
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instructions, plant change forms, calibration data packages, test
instructions, and test control forms.
Review of this item is complete for
Unit 1.
The precision calibrations for the Unit 2 flow instrumentation are scheduled for completion during December 1993. This item will remain open pending completion of the Unit 2 precision calibrations.
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3.4 JClosed) IFI 498/9331-68: 499/9331-68:
Postmaintenance Testing Program Restructured t
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i This IFI involved the licensee's restructuring of the PMT program because of programmatic and implementation weaknesses. The previous program did not
differentiate between PMTs and operability tests well enough, and-the PMT -
reference manual caused confusion.
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In corrective actions to remedy problems associated with the PMT program, the
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e licensee developed a new PMT program procedure guidance (OPGP03-ZM-0025, Revision 4), a revised PHT reference manual (Revision 8), and a revised work
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process program procedure (OPGP03-ZA-0090, Revision 7) (Attachment 2). The
'l restructured PMT program placed the primary responsibility of developing the r
appropriate PMT requirements with the maintenance planners.
Postmodification
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testing requirements resided with the engineering departments. Other testing requirements such as operability and special testing were assigned to the responsible department (e.g.; operations). The new program segregated PMTs from operability tests and provided allowances for waiving the PMT with an operability test.
PMT requirements were reviewed and authorized by the WSA
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(e.g.; OWCG or Chemistry Operations Supervisor) prior to their implementation.
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As such, the WSA was allowed to waive certain PMTs when subsequent operability
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tests verified the waived PMT attribute (s). Operations then became
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Operability tests or other special test were initiated and processed by the use of a testing form, Addendum 1 of OPGP03-ZM-0025. At the time of this inspection, the restructured PMT program appeared to resolve problems
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identified with the previous PMT program.
Ilowever, some confusion with respect to PMT administrative processing may have remained.
For example, during a training class observed by the inspectors on
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the PMT program with licensed operators, there appeared to be confusion as to i
which department would retain deferred PHTs for plant or system readiness.
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Some operators believed the 0WCG would retain the work packages while others
believed the packages would be returned to planning and the responsible craft until the new work window came up in the schedule. Additionally, the operators were uncertain as to the linkage between the operability test form and any waived PMTs. While some believed that reference would be made on the test forms, others believed that in order to reference the link, the work management system would have to be reviewed.
These and other administrative PMT and work process issues were under review by the licensee at the time of this inspection. The licensee was evaluating implementation of further
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administrative enhancements to the program.
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3.5 (0 pen) IFI 498/9331-69: 499/9331-69: The Licensee's Response to Bulletin 88-08. " Thermal Stresse; in Piping Connected to the Reactor Coolant System"
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NRC Bulletin 88-08 was initiated to address identified cracking in piping connected to reactor coolant piping (i.e.; normal charging line, alternate
charging line, auxiliary spray line, and residual heat removal lines) caused
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by thermal stratification, thermal striping, and thermal cycling. The licensee, by letter dated September 28, 1988, addrcssed actions to ensure that the piping would not be jeopardized, including installation of temporary instrumentation to provide continuous monitoring of the systems for leakage pathways. The monitoring of the piping would also detect adverse temperature j
distribution and establish appropriate limits on temperature distribution.
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Subsequent to instrumenting the lines, the licensee separately analyzed and
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requalified the alternate charging, normal charging and the auxiliary spray lines for thermal stratification. Thermal cycling was not considered a i
significant prdlem because of design (i.e.; critical weld locations being approximately Tipe o.eneters from the reactor coolant loop nozzles). The
residual heat removal lines had been previously evaluated and found acceptable j
for the life of the plant.
l The licensee used the: analyses as bases for dismantling the temporary monitoring instrumentation and informed the NRC'of this decision by letter dated September 21, 1990.
Subsequent NRC review determined that the licensee was premature in dismantling the temporary monitoring instrumentation, and the evaluation using 20 pipe diameters was inconsistent with published data that showed possible turbulence penetration up to 23 pipe diameters.
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Ongoing discussion between the licensee, Westinghouse Electric Corporation (the nuclear steam supply system manufacturer), and the Office of Nuclear Reactor Regulation resulted in an agreement to meet at Westinghouse facilities in Pittsburgh, Pennsylvania, during November 8-10, 1993. The purpose of the meeting is to discuss the licensee's position regarding thermal monitoring of unisolable piping connected to the reactor coolant system. Therefore, this item remains open pending the results of that meeting.
4 ONSITE REVIEW OF LERs (92700)
4.1 (Closed) LER 498/92-004:
Shunt Trip Contacts for Manual Reactor Trio Breakers Not Tested Per Technical Specifications-The licensee identified that a surveillance test procedure used to test the manual reactor trip function did not adequately test all contects associated with the handswitches used to initiate a manual reactor trip via the shunt trip device.
The licensee determined the root cause of this condition to be the unfamiliarity of the individual responsible for developing the original procedure with the reactor trip feature. A contributing factor was inadequate review of the procedure during various review cycles.
The licensee committed to the following corrective actions: develop a temporary procedure to test the manual reactor trip via the shunt trip device; revise the permanent procedure to address the necessary testing; submit a request for a temporary waiver of compliance and an emergency lechnical Specification amendment to provide for a schedule change regarding the performance of testing prior to restarting from the first planned or unplanned shutdown occurring subsequent to May 19, 1992; and review all applicable
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surveillance procedures to ensure compliance with Technical Specification requirements.
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The inspectors reviewed the licensee's actions taken to implement the above commitments.
Permanent Procedure OPSP03-RS-0002, " Manual Reactor. Trip TADOT (Trip Actuating Device Operational Test)," Revision 0, was issued on October 19, 1992, and superseded and combined the separate procedures established for each unit.
Temporary Procedure OTSP03-RS-0002, " Manual Reactor Trip TAD 0T," Revision 0, became effective on May 22, 1992. Unit I did not enter an outage between the time the commitment was made and commencement of the fourth refueling outage on September 19, 1992.
Since the permanent procedure was revised and approved prior to the completion of the fourth refueling outage, it was used for testing Unit I rather than the temporary procedure. Unit 2 was tested using the temporary procedure during an unplanned outage on December 27, 1992.
It is also planned to test Unit 2, using the permanent procedure, prior to the completion of the current third
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refueling outage. The NRC granted a written Temporary Waiver of Compliance to Technical Specification 4.3.1.1 on May 21, 1992, and Amendments 37 (Unit 1)'
and 28 (Unit 2) to Technical Specification 4.3.1.1 were approved by the NRC on June 2, 1992. A Surveillance Review Task Force was assembled to conduct a l
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engineered safety features and the applicable surveillance procedures.
The purpose of the review was to identify any additional cases where testing was either being performed incorrectly or not at all. The final report, which was issued February 1,1993, revealed that 16 Station Problem Reports were initiated to identify potential Technical Specification adherence problems.
Four of the 16 station problem reports were determined to be reportable and corrective actions were established and implemented.
The inspectors were made aware that the licensee had committed, in responses to inspection reports, other LERs, and the operational readiness plan, to conduct an extensive surveillance procedure enhancement program. The program-is currently underway and scheduled for completion by the end of 1996.
4.2 LClosed) LER 498/92-014:
Containment Ventilation Isolation Occurred Frior to Expected Actuation During Surveillance Test
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The licensee's evaluation of the condition determined the isolation to be a result of a less than adequate procedure that allowed a premature high radiation signal actuation during test conditions. The hardware root cause
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was an artificially established low, high-alarm-setpoint.
The committed corrective actions included:
review and revise Test Procedure 1 PSP 03-SP-0016, " Containment Ventilation Isolation Actuation and
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Response Time Test," Revision 0; and review and evaluate all surveillance and maintenance procedures used to test containment ventilation isolation actuations on simulated high radiation signals for both units.
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The inspector reviewed the corrective actions taken by the licensee to verify completeness and adequacy. Test Procedure 1 PSP 03-SP-0016 was revised in Field Change FC92-0549 dated September 28, 1992, to modify the high alarm setpoint
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calculation and incorporate steps to compare calculated setpoint with actual
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monitor readings. The licensee's review of other procedures identified the need to revise five additional surveillance procedures used to test engineered safety features actuations on simulated high radiation signals. The
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inspectors noted that four of the five procedures had been revised (i.e.,
OSP14-RA-Ill3, OPSP14-RA-lll4,1,2 PSP 03-HF-0001, and 1,2 PSP 03-HF-0002) with the last one (0 PSP 03-HE-0001) scheduled for completion by November 30, 1993.
Additionally, the licensee identified six maintenance procedures (i.e.,
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OPSP02-RA-8012, -8013, -8033, -8034, -8035, and -8036) which had the potential for allowing premature high radiation signal actuation of engineered safety
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features.
These procedures were revised to incorporate dual verification of
setpoint establishment. These actions should preclude premature actuation and
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still allow for the test objectives to be met.
I 4.3 (Closed) LER 498/92-016:
Unplanned ESF Actuation of a CCW Pump This LER involved an unplanned engineered safety feature actuation due to a
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low level in the CCW surge tank resulting from a failure to reopen the CCW
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surge tank makeup valve following a chemical addition.
The root cause of the
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event was identified as less than adequate communications and a lack of a procedural step to verify valve position.
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The licensee identified as corrective actions the following measures:
Discussion and training on the event was incorporated into
requalification training for licensed operators, nonlicensed operators,
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chemical operators, and chemistry technicians.
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Procedures associated with chemistry activities concerning the CCW l
system were revised.
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A review of procedures involving operations and chemistry interfaces to
ensure adequate independent verification of valve positioning was accomplished.
Preventive maintenance (PMs) for the Unit I low level alarm switch CCW
surge tank was reactivated and Unit 2 implemented as of January 28, 1993.
L A review of PMs associated with control room annunciators to determine l
whether the annunciator instrument loops receive a periodic calibration was performed.
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At the time of this inspection, the proposed corrective actions of the l
licensee had been completed and were adequate. The last corrective action i
listed above involved developing a list of control room annunciators whose
instrument loops were not calibrated to operations procedures, identifying
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which ones required calibration inputs, and initiation of PMs for the
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associated instruments. These cctions were scheduled for completion by l
December 31, 1993.
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ATTACHMENT 1 PERSONNEL CONTACTED l
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Houston Lighting & Power Personnel
- J. Blevins, Supervisor, Records Maintenance Services
- B. Bragg, Maintenance Planning Supervisor
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- B. Caldwell, Assessor, Planning & Assessment
- J. Calloway, Planning & Assessment
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- T. Cloninger, Vice President, Nuclear Engineering
- W. Cottle, Group Vice President
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- R. Ferguson, Contractor, Licensing
- J. Groth, Vice President, Nuclear Generation i
- J. Gruber, Unit 1 Work Controller
- H. Hesidence, Ir. dependent Safety Engineering Group Engineer
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- T. Jordan, General Manager, Nuclear Engineering
- W. Jump,. Assistant to Group Vice President
- D. McCallum, Operations Superintendent, Operations
- W. Mookhock, Unit 1, Assistant Operations Manager
- L. Myers, Unit 1 Plant Manager i
- P. Parrish, Senior Specialist, Nuclear Licensing
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- S.
Rosen, Vice President, Industrial Relations i
- P. Schimpf, Assessor, Planning & Assessment
- L. Taylor, Project Manager, Maintenance Support
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- J. Wells, Shift Supervisor j
1.2 NRC Personnel l
- D. Garcia, Resident Inspector
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- J. Keeton, Resident Inspector In addition to the personnel listed above, the inspectors contacted other personnel during this inspection period.
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- Denotes personnel present at the exit meeting.
2 EXIT MEETING
An exit meeting was conducted on October 29,'1993. During this meeting, the
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inspectors reviewed the scope and findings of the inspection. The licensee did not identify as proprietary any information provided to, or reviewed by,
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the inspectors. The licensee acknowledged the inspectors' findings from the inspection.
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ATTACHMENT 2 DOCUMENTS REVIEWED Station Procedure OPGP03-2M-0025, " Post-Maintenance Testing Program,"
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Revision 4, dated September 17, 1993 Station Procedure OPGP03-ZA-0090, " Work Process Program," Revision 7,
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dated August 24, 1993 Department Procedure, " Post Modification Acceptance Testing Guidelines,"
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Revision 0, dated March 2, 1992
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Department Procedure, " Post-Maintenance Testing Reference Manual,"
Revision 8, dated September 17, 1993 i
Internal Memoranda from Unit 1 Assistant Operations Manager to Unit 1
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Shift Supervisors and Unit Supervisors; Subject: " Operability Testing,"
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dated October 25, 1993
In addition to the above, other documents not listed were reviewed during the
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inspection.
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