IR 05000498/1993045
| ML20059J753 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/24/1994 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059J740 | List: |
| References | |
| 50-498-93-45, 50-499-93-45, NUDOCS 9402010152 | |
| Download: ML20059J753 (45) | |
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APPENDIX ,
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report: 50-498/93-45 -
50-499/93-45 ,
Operating License: NPF-76 NPF-80 Licensee: Houston Lighting & Power Company P.O. Box 1700 Houston, Texas 77251 Facility Name: South Texas Project Electric Generating Station, Units 1 and 2
Inspection At: Matagorda County, Texas Inspection Conducted: November 7 through December 18, 1993 Inspectors: D. P. Loveless, Senior Resident Inspector D. M. Garcia, Resident Inspector D. N. Graves, Senior Resident Inspector, CPSES l J. M. Keeton, Resident Inspector R. B. Vickrey, Reactor Inspector G. E. Werner, Resident Inspector, CPSES J. E. Whittemore, Reactor Inspector P. A. Goldberg, Reactor Inspector D. B. Spitzberg, Ph.D., Emergency Preparedness Analyst Approved: //A -
% V U- # N W.D.J,ag'nson, Chief,ProjectSectionA Date Divisi6fi of Reactor Projects Inspection Summary ,
Areas Insppsfari (Units 1 and 2): Routine, unannounced inspection of plant -
status, ors t ta 'ollowup of events,-operational safety verification, '
maintenance gar surveillance observations, followup of corrective actions for a violta 1N. and an open item, and special, announced inspections of the - a follow ng restart issues: (1) engineering backlog, (2) fire prevention and l protection, and (3) system certification revie ;
r 9402010152 940125 PDR ADOCK 05000498 G PDR
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Results (Units 1 and 2):
- One noncited violation was identified for failure to properly control the work activities involving 13.8 KV Switchgear 2 Corrective actions following the event were' comprehensive and .'
timely. This was considered a wrong component event (Section 2.1).
- Licensed operators conducted their duties in a profesrional manner. Shift turnovers were thorough (Section 3.1).
- The general material condition of the plant was significantly improved (Section 3.2). ,
- A security system failure was compensated for efficiently and in a timely manner (Section 3.3).
- Motor-operated valve actuator technicians performed maintenance on i the wrong valve actuator. This was considered another wrong i component event, with generic corrective actions considered ,
necessary to correct this recent trend. This violation was cited !
in NRC Inspection Report 50-498/93-54; 50-449/93-54 (Section 3.4).
- The restoration of power to IE busses in Train A was well i coordinated and controlled (Section 3.5).
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- Independent verification of lifted leads in a standby diesel generator control cabinet was not rigorously performed (Section 4.1).
- Generally, observed work on motor-operated valve actuators was ,
considered of good quality and well controlled (Section 4.2).
- The attention to detail of craftsmen repairing a solenoid-operated -
valve was good following the identification of water intrusion into a termination box (Section 4.3).
- A test of standby diesel generator slave relays was performed in 1 an acceptable manner; however, the procedure appeared to be- .,
confusing (Section 5.1).
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- Technicians performing an inservice test identified discrepancies between test and process instruments. This level of attention to detail was considered good (Section 5.2). ,
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- Technicians were required to rely on skill-of-the-craft as opposed to plant component identification to perform a test on nuclear instruments (Section 5.3). ;
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- Rescart Issue S, involving the backlog of engineering items, remained open pending further NRC inspection (Section 6).
- Licensee management efforts to reduce the backlog of fire protection system deficiencies were considered good (Section 7.2).
- Restart Issue 8, involving the adequacy of the fire protection computer and other Fire Protection Hardware Problems was-determined to be resolved (Section 7.3).
- Minor discrepancies noted during system walkdowns were' addressed and corrected by plant management (Section 8.2).
- A leak sealant clamp was identified on Residual Heat Removal (RHR)
Pump C discharge flange. Plant management committed to removing the clamp before Unit I restart (Section 8.2).
- Observed system walkdowns and verification inspections performed ;
i indicated that the licensee's system walkdown had been effective (Section 8.2).
- Although the licensee's system certification walLdown punchlist contained some items requiring a service request be initiated, the licensee was performing the work in a controlled manner and had shown considerable progress toward closing the punchlist (Section 8.3).
- Restart Issue 13. " Monitoring of the Licensee's System ,
Certification Program," was determined to be resolved (Section 8.4).
- Two previous emergency response drill weaknesses were closed based on licensee corrective actions (Section 9).
- Management was found to have performed effectively in identifying and correcting problems involving specific restart issues (Sections 6.22, 7.2, and 8.6).
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Summar_y of Inspection Findings:
- Inspector Followuo Item (IFI) 498;499/93031-81 was closed (Section 6.1). !
l e IFI 498;499/93031-30 remained open (Section 6.2).
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- IFI 498;499/93031-40 was closed (Section 6.3).
- IFI 498;499/93031-41 remained open (Section 6.4).
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- IFI 498;499/93031-42 remained open (Section 6.5).
- IFI 498;499/93031-52 was closed (Section 6.6).
- IFI 498;499/93031-31 was closed (Section 6.7). J
- Violation 498;499/93008-02 was closed (Section 6.8).
- IFI 498;499/93031-08 remained open (Section 6.9).
- IFI 498;499/93031-19 was closed (Section 6.10).
- Violation 498;499/93008-04 was closed (Section 6.11).
- IFI 498;499/93031-77 was closed (Section 6.12). '
- IFI 498;499/93031-64 was closed (Section 6.13).
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- IFI 498;499/93031-18 remained open (Sections 6.14 and 6.15). -i e IFI 498;499/93031-48 was closed (Section 6.16).
- Licensee Event Report (LER) 499/92-004 was closed (Section 6.17).
LER 498/92-020 was closed (Section 6.18). ,
- IFI 498;499/92035-01 was closed (Section 6.19). ,
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- IFI 498;499/93031-49 was closed (Section 6.20).
Violation 499/93015-01 was closed (Section 6.21). ,
- IFI 498;499/93031-02 remained open (Section 7.4.1). -
- IFI 498;499/93031-17 was closed (Section 7.4.2).
- IFI 498;499/93031-22 was closed (Section 7.4.3). ,
- IFl 498;499/93031-75 was closed (Section 7.4.4). ,
- IFI 498;499/93031-35 was. closed (Section 8.5.1).
- IFI 498;499/93031-53 remained open (Section 8.5.2).
- Open Item 498;499/91003-01 was closed (Section 9.1). ,
e Violation 498;499/91014-01 was closed (Section 9.2).
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Attachment:
.* Attachment 1 - Persons Contacted and Exit Meeting ,
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-6-DETAILS 1 PLANT STATUS 1.1 Unit 1 Plant Status At the beginning of this inspection period, the Unit I reactor was shutdown and defueled, with preparations under way to reload the reactor core. On November 18, 1993, the first fuel assembly was placed in the reactor vessel indicating entry of the unit into Mode The fuel movement was completed on November 21, 1993, with the reactor core fully loaded. The reactor vesse head was tensioned and the unit entered Mode 5 on November 26, 1993. At the end of this inspection period, Unit I was in Mode 5, in Day 317 of the forced maintenance outag .2 Unit 2 Plant Status At the beginning of this inspection period, the Unit 2 reactor was shutdown and defueled. At the end of the inspection period, Unit 2 was defueled and in Day 294 of the refueling outag ONSITE FOLLOWUP OF EVENTS (93702) Inadvertent Trip of Circulating Water Pump 21 (Unit 2)
On November 8, 1993, while preparing for routine maintenance on the Unit 2 auxiliary transformer, the undervoltage coil for 13.8 KV Switchgear 2F was inadvertently deenergized. The incident occurred because of poor labeling _ on the switchgear cubicles. The electricians were confused by the labeling on the potential transformer drawers in Cubicle 13 and could not determine which drawer needed to be removed from service to satisfy the equipment clearance order. The electrical supervisor referred to a one-line electrical drawing and determined that both drawers should be taken out of service to be conservative. When the upper drawer was removed, Circulating Water Pump 21 tripped. Because the unit was in cold shutdown, the only component that tripped was Circulating Water Pump 21. Had the unit been operating, Reactor Coolant Pump 1A, Condensate Pump 21, and Feedwater Booster Pump 21 would have tripped resulting in a reactor tri Subsequent investigation revealed ~that a similar event had occurred in 1991 as documented in Station Problem Report 91006 The corrective actions recommended at that time were ineffective in preventing this occurrenc However, this event occurred in excess of 2 years ago, and the licensee has taken significant actions since then to improve the development of corrective actions to be taken in response to station problem reports. The actions taken in response to the most recent event included:
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- Properly labeling the switchgear cubicles and drawers for all 13.8 KV buses in both unit * Enhancing the equipment clearance order data base nomenclature to reflect exactly what each drawer containe ;
- Including continuing training on how to properly remove electrical control equipment from service including reviewing the protective relay '
schem The inspector checked all 13.8 KV switchgear cubicles on both units and found ,
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that they had been relabeled. Large plaques identified what components were contained within the' drawer as well as the consequences of opening the drawe The corrective actions taken should preclude recurrence of the even '
Failure to properly control work activities and provide adequate labeling to perform such tasks was a violation of licensee requirements. However, this item will not be cited because of the licensee's actions met the criteria delineated in Paragraph VII.B.2 of Appendix C to 10 CFR Part 2 of the NRC's,
" Rules of Practice." However, this event was viewed as another wrong component even Further dicussion on the operation of wrong components were addressed in Section 3.4 of this repor .2 Conclusions Response to this event was prompt. An adequate root cause evaluation wa',
conducted. Corrective actions appeared to be comprehensive and tirnl OPERATIONAL SAFETY VERIFICATION (71707)
The objectives of this inspection were to ensure that this facility was being operated safely and in conformance with license and regulatory requirements, and to ensure that the licensee's management controls were effectively discharging the licensee's responsibilities for safe operation. The following paragraphs provide details of specific inspector observations during this- <
inspection perio ,
3.1 Control Room Observations Throughout this inspection period, the inspectors made. routine, daily control'
ra.m. tours. The licensed operators conducted their duties in a professional e...aer and .ture attentive to plant parameters. Operators responded to .;
annunciators in a timely manner and were aware of the. reason for lit .
annunciators. Extraneous activities in the Unit I control room have been reduced, and a reduction in-the associated noise levels has been note ,
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On November 18, 1993, licensed operators initiated fuel inovement and took the Unit I reactor into Mode 6. Prior to the mode change, the inspectors reviewed the licensee'r operability tracking log and determined that Technical
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-8-Specification requirements were being met. A sample of Mode 6 applicable limiting conditions for operation were reviewed to ensure that necessary equipment was available to support Mode 6 operation On November 26, 1993, the reactor vessel head was tensioned and the unit entered Mode Again the inspectors reviewed the operability tracking log and a sample of Mode 5 applicable limiting conditions for operation. In addition to a walkdown of the control panels for proper switch positioning, the inspectors verified: that the reactor coolant system was properly vented in accordance with Technical Specification 3.4.9.3; that the reactor trip breakers were open because the digital rod position indication system was inoperable as prescribed by Technical Specification 3.1.3.3; and, a local verification was performed to ensure that Reactor Water Makeup Valve ICV-0198 -
was locked in the throttled position required by Technical Specification 3.4.1. No discrepancies were note The inspectors observed main control board walkdowns during shift turnover on numerous occasions. The information passed on was thorough and included reasons behind the indications discussed. The inspectors verified that Technical Specifications action statements were being complied with were appropriately highlighte .2 Plant Tours lhroughout the inspection period, the general material condition of the plant was significantly improved. Improvements were noted by fewer instruments being out-of-service, deficiencies noted had been previously identified, and the absence of fasteners on panels and cabinets had been greatly reduce Additionally, safety-related buildings had been sealed to reduce the penetration of ground water, and coatings were being upgraded on several plant systems. However, housekeeping still needs improvement, particularly in the radiological controlled area. Material was left behind following maintenance activities. Additionally, there was used tape, cotton, and rubber gloves found laying on benches and on the floo On December 16, 1993, while performing a routine control room observation, the inspector found a ladder stored in the overhead space above the control roo This was brought to the attention of the shift supervisor. He was not aware of any work in progress and stated that it was operations policy that stored material above the control room was not allowed. The ladder was removed promptl .3 Security Observations On December 15, 1993, the emergency security system experienced a partial loss of power, resulting in total system failure that disabled the vital area card readers. Security personnel implemented Procedure OSDP01-ZS-0010, Revision 13, " Contingency and Compensatory Response." The posting l requirements were met within the required timeframe. The inspectors observed
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the evolution and concluded that the security force was timely and efficient i in processing plant personne .4 Review of Maintenance Performed on Wrong Component On November 22, 1993, a crew performing inspections and maintenance on Unit 2 valve motor operators performed work on the wrong valve. Operators had prepared equipment clearance orders and released the equipmer,t for the crew to repair the motor operators for Containment Spray System Valves 2CS-MOV-0001A and 2CS-MOV-0001B. However, the crew mistakenly began the work on Safety Injection System Valves 2SI-MOV-0001A and 2SI-MOV-00018. These valves had similar valve designators but were in different plant system Prior to this event, on November 22, 1993, day shift personnel from the licensee's contractor were assigned to perform a preliminary inspection of the limit switch assemblies for Valves 2CS-MOV-0001A and 2CS-MOV-00018. Day shift personnel completed the inspection and corrected minor deficiencies but were unable to complete the final close-out inspection. This close-out inspection ,
was turned over to the night shift for completio The night shift personnel received work start approval from the control room and health physics to perform the final close-out inspections on Valves 2CS-MOV-0001A and 2CS-MOV-0001B. The technicians signed the applicable radiation work permit and proceeded to the area where the valves were locate Upon arriving at the work site, the crew realized that the first valve was located inside what appeared to be a contaminated zone. A contractor technician contacted a health physics technician to determine exactly what the radiation protection requirements were to work on the valve. After the boundaried area was described to the shift health physics tech;cian, they ,
were informed that as long as they did not step on the floor, they were not required to dress in anticontamination clothing to complete the jo The technician stated that he verified the last 5 characters of the tag on the valve to ensure that he was working on the "0001A" valve and proceeded to ,
< remove the limit switch cover and conduct the inspection and correct deficiencies found. It should be noted that several other physical differences existed that should have indicated that the wrong valve had been identified. The safety injection valves were 16 inches in diameter and have a different actuator type than the 8-inch containment spray valve The crew later stated that the valves they worked on had similar. problems to those documented by the day shift. Therefore, they corrected the deficiencies assuming the day shift package had been inaccurate. Upon completion of the deficiency correction, the contractor's quality control inspector and an Houston Lighting & Power (HL&P) quality control inspector conducted a final close-out inspection of the valve. These inspections were completed and required signatures were entered in the work package. In addition, a design engineering department representative observed the work and inspected a chip that had been identified within the limit switch assembly. Again, this
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While conducting routine operator rounds,. the mechanical auxiliary building reactor plant operator reviewed the crew's work packages and asked if the valves were tagged out under the equipment clearance program. The operator was informed that the valves were tagged out. The package review by the operator was conducted while the technicians were working on Valve Actuator 2SI-MOV-0001A. The operator proceeded to the control room and identified that the safety injection valves did not appear to be under an equipment clearance order. The reactor plant operator. informed shift supervision that the contractor personnel had worked the wrong valve Plant General Procedure OPGP03-ZA-0090, " Work Process Program," Step 3.7.2.16, required that, " Work group personnel shall verify that station component identification matches the component specified as requiring maintenance in the work document." The failure of the technicians to verify the complete component number on the identification tag was a violation which was cited in NRC: Inspection Report 50-498/93-54; 50-499/93-5 In addition to this specific violation, a number of barriers that could have >
precluded the errors were identified as missed. These items were of regulatory significance but will not be cited individuall However, the licensee's response to this violation should include a discussion of the causes and corrective actions for the failure of each barrier to preclude the occurrence of this event. The specifics of the barriers, the human factors associated with the event, and other wrong component events occurring on site will be.further reviewed and discussed in NRC Inspection. Report 50-498/93-54; 50-499/93-54. Each barrier has been discussed briefly below:
- The contractor personnel were allowed to work independently and expected to follow HL&P's work control process and other administrative requirements. However, they did not receive specific training in the ,
requirements of HL&P's administrative progra >
- Work supervisors were not able to easily ensure that personnel had the experience or certifications required to perform a given work tas '
. According to an interview, the work supervisor did not perform a prejob briefing utilizing a briefing checklis * The night maintenance shift supervisor accepted.the equipment clearance order during turnover but did not assure that the boundary was adequate for the work intended by his cre * The work group did not report to supervision that the job site .
conditions differed from the expectation l
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+ Health physics technicians did not adhere to radiological procedure The contaminated zone boundary should have been moved or a different ,
radiation work permit should have been used to work in the conditions identified by the work cre * The work crew did not perform electrical safety checks to assure that clearance order boundaries were adequate as required by HL&P and the contractor's safety manual * Day-to-day monitoring of vendor performance was required by HL&P procedure. However, this monitoring, if it was performed, did not detect deficiencies in adherence to work and inspection procedure The licensee determined that the root cause of this event was the inattention to detail and the lack of self-verification by the technicians involve The valve labeling was clear, the components were specifically addressed in the work package, and the discrepancies noted in the work package as being previously corrected still existed in the valve actuator. The licensee, therefore, concluded that the event was caused by technician erro As corrective actions the licensee performed the following:
(1) All motor-operated valve actuator group field implementation personnel were trained on the following:
- Self-verification program concepts
- Equipment clearance order verification
. The contractor's work traveler implementation <
- HL&P service request format -
- General HL&P work practices
. The event scenario and safety hazards (2) The contractor's work package traveler was modified as follows:
- Require independent double verification of component identification prior to work start of each shif * Require use of a voltage potentiometer to verify energization status of exposed circuitr ,
e Require independent double verification of the equipment clearance !
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order prior to work start of each shif '
(3) Expectations for the performance of work for all positions within the field implementation area of the motor-operated valve actuator group were defined. These expectations were presented to every employee within the organization, and a contract amendment was initiated to include the applicable expectations within the contract.
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-12-(4) The field implementation area of responsibility was redefined. The maintenance department was given the responsibility for the field activities associated with the motor-operated valve actuator program as opposed to the design engineering organization. Additionally, senior maintenance department personnel were added to the field implementation area to provide oversight and assurance that work expectations were me (5) The contractor's onsite organization was redefined to facilitate thorough shift turnovers and provide increased field supervisio '
(6) The design engineering department representative was replaced with an HL&P permanent employee as opposed to a contract employe The inspectors expressed concern that the lack .of self-verification, as viewed by this and several other recent events referenced in this report, was not restricted to the specific contractor. The licensee should evaluate recent wrong component events and consider the need for more generic corrective actions to address problems with self-verification as conducted by South Texas Project employees and contract personne .5 Restoration of Power to E1A Electrical Buses On December 2, 1993, the inspector observed the restoration of power to electrical busses powered from Electrical Distribution Center EIA. The busses had been de-energized for electrical Train A outage work. Many of the-breakers in the busses had been refurbished and replaced. The process of re-energizing the busses was very well organized and all individuals involved were briefed on proper procedures and expectations of equipment-performanc All breakers that had maintenance performed were cycled prior to energizing the busses. Prior to energizing the bus, all personnel were evacuated from the rooms containing the electrical busses and from the vicinity of the transformers being energize A special procedure for testing the refurbished breakers and for energizing the busses had been developed. The operators identified a need for development of a generic procedure for energizing an electrical-train. This recommendation was provided to the procedures group. Loading of the individual 480 VAC busses was performed in accordance with the applicable operating procedure. No problems were encountered during power restoratio .6 Conclusions Overall, plant operations, including control room operator professionalism, shift turnover, and plant material condition improved significantly over the inspection period. Some poor housekeeping items in the radiological controlled area continue to exist. One case of technicians performing -
maintenance on the wrong valve was cited as a violation in NRC Inspection ,
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Report 50-498/93-54; 50-499/93-54. Generic corrective action for this event, in addition to other wrong component events, were considered to be necessar .
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-13-4 MONTHLY MAINTENANCE OBSERVATIONS (62703)
The station maintenance activities addressed below were observed and documentation reviewed 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 activities were conducted in accordance with approved work instructions and procedures, the test equipment was within the current calibration cycles, and housekeeping was being conducted in an acceptable manner. Activities witnessed included work in progress, postmaintenance test runs, and-field walkdown of the completed activities. Additionally, the work packages were reviewed and individuals involved with the work were interviewed. All observations made were referred to the licensee for appropriate actio .1 Standby Diesel Generator 21 Starting Relay Replacement Electrical maintenance technicians were observed replacing Standby Diesel Generator Relay 4EX3 which was danger tagged out in accordance with Work Activity 92040315. Form OPGP03-ZM-0021-1, " Configuration Change Log," was the governing document that controlled wiring configuration during the lifting and landing of the electrical lead During the inspectors' observations, it was not readily apparent that verification of lifted leads required by Procedure OPGP03-ZM-0021, Revision 4,
" Control of Configuration Changes," was performed for several leads. One technician was observing the wire and terminal identification numbers and relaying those numbers to another technician who entered the data on the configuration log. The inspectors did not observe the second technician verifying terminal identification numbers; however, after questioning the technician, he indicated that he had looked at the terminal markings prior to the inspectors arrival, and, therefore, performed verification. A quality control inspector verified the leads were reinstalled in accordance with the log. The technicians did maintain proper wiring configuration control during the removal and installation of the rela y Review of Motor-0perated Valve Actuator Activities
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4. Repair of RHR Pump Suction Valve The inspectors reviewed the work package for Work Authorization No. 93034566 associated with Service Request RH-1-211898 for Valve IRH-MOV-0061C, the RHR ,
Pump IC suction valve from Reactor Coolant System Loop 3 hot. leg. Although not released' for work in the field, the package was reviewed for staging and ,
job planning preparation. The work order was found to be thorough with all procedures either included in the package or referenced for us Postmaintenance testing was identified on a postmaintenance' checklist with the required retests clearly identified. The identified testing was appropriate for the planned scope of work on the actuator. A Radiation Work Permit-93-1-0767 and Equipment Clearance Order 1-93-4781 had been generated for the task and were referenced in the documen " * ~ ~ ~
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-14-4.2.2 Disassembly of a Containment Purge Valve Actuator The inspectors observed portions of the disassembly of Valve Actuator 1HC-MOV-0003, a containment purge supply isolation valv The disassembly was being performed under Work Authorization No. 93023447. The technicians utilized good work practices during the observed gear and housing disassembly and cleaning. The motor pinion key was observed to be sufficiently staked to prevent dislocation; an1 the removed components were properly segregated, identified, or otherwise Lnder direct physical control of the technicians. A review of the work order irdicated that the postmaintenance testing was identified in a different format from that identified in Section 4.2.1 above. The postmaintenance test guide had been revised following the generation of this work order, and the package referenced in Section 4.2.1 reflected the new forma Verification sheets in the work package had been completed on each shift and indicated continuing self-verification of ongoing activities associated with this actuato ,
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4. Disassembly of a Component Cooling Water Actuator Spring Pack The inspector observed the disassembly of the spring pack from Valve Actuator ICC-MOV-0032, the Unit I component cooling water system supply to the spent fuel pool isolation valve. This was being performed under Work Authorization No. 93006902. In addition to the spring pack disassembly, the inspector observed the implementation of Limitorque Maintenance Update 88-2 regarding grease relief flow paths on the thrust washer and the torque limit '
sleeve. During the machining of the sleeve, the end mill cutting tool broke cutting the outside surface of the sleeve adjacent to the machined slot. The technician labeled the sleeve with a maintenance hold tag, identified the deficiency to his supervisor, and generated Discrepancy Report 2-STP-618 in accordance with the contractor's Quality Assurance Procedure, QAP 15.1,
" Discrepancy Reporting," Revision The work document was revieved and the signatures.were found to be up to dat The disassembled components were properly segregated, identified, or.under physical control of the technician. Good work practices and safety precautions were utilized by the technician
4.3 Observation of Solenoid-0perated Valve Repair The inspector observed part of the performance of Service Request SI-1-157109,
" Repair or Replace Badly Corroded Fittings on Conduit and Valve FY-3983."
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Accumulator Nitrogen Supply Header Isolation Valve A1SI-FY-3983 had been identified as needing replacement. The inspector observed the' replacement of the solenoid and termination of the cables. Additionally, Raychem heat shrink was used to seal the termination During the evolution, workers identified what appeared to be boric acid l crystals present inside the box, a condition that would indicate water
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-15- t intrusion. Craftsmen documented the condition for repair and noted that the condition could cause the equipment to be inoperable. The inspector determined that the craftsmen had been alert and made an excellent evaluation and documentation of a condition adverse to qualit The inspector indeper.dently verified the diameter of the wires terminated and that the heat shrink applied met the manufacturer's recommendations. The inspector also. verified that the minimum bend radius of the cable was maintaine The craftsmen appeared to be knowledgeable of the work and its requirement The crew foreman was present and observed a portion of the installation. A ;
quality control inspector was also present and independently verified ,
installation parameters, proper parts usage, and equipment identific& tio The inspector reviewed Quality Control Inspection Report 93-1-3595, which documented quality control oversight for this maintenacne activity and found no discrepancie .4 Conclusions One observation indicated that independent verification of lifted leads was not being rigorously performed. During another observation, workers identified a safety-significant problem while performing routine maintenanc This action was considered an excellent level of attention to detai The observed activities regarding motorized valve actuator maintenance, including work package preparation and utilization, indicated that the work activities were generally well planned with proper postmaintenance testing identified. The technicians employed good work practices, were knowledgeable of the tasks and the equipment, and were familiar with the deficienc reporting process as evidenced by the observed implementatio Overall, during this inspection period, maintenance activities observed were performed in a good manne BIMONTHLY SURVEILLANCE OBSERVATIONS (61726)
The inspectors observed the surveillance testing of safety-related systems and components addressed below to verify that the activities were being performed; '
in accordance with the licensee's approved programs and the Technica Specification .1 Standby Diesel Generator 22 Slave Relay Test ;
On November 29, 1993, the inspector observed an emergency start test of Standby Diesel Generator 22 by actuation of the safety injection slave rela The test was performed in accordance with Procedure OPSP03-SP-00llB, " Trai Diesel Generator Slave Relay Test." The operators and technicians involved in
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the test. A pretest briefing and a " dry run" were conducte :
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-16-The inspector verified that the calibration of the Fluke Model 77 digital multimeter was current. The procedure used for conducting the test was adequate, but was found to have extraneous information that could cause confusion. The operator submitted a feedback form to remove contact numbers from the procedure, which simplified the procedur The test was acceptabl All switen manipulations and readings taken were verified by the unit superviso .2 Inservice Test for Spent Fuel Pool Cooling Pump 1A
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On December 1, 1993, the inspector observed the inservice test of Spent Fuel Pool Cool System Pump 1A in accordance with Plant Surveillance Procedure IPSP03-FC-0002, " Spent Fuel Pool Cooling Pump 1A Inservice Test."
The test and data collection were observed locally. The inspector verified that the calibration of all temporary gauges and instruments was curren Personnel involved in the test demonstrated task proficiency and good system knowledg During the test, the technicians noted a discrepancy between indications from the installed Suction Pressure Gauge PI-1405 and the temporary test gaug The process instrument appeared to be reading 1.5 psig more than the test gauge. A request to recalibrate Pressure Indicator PI-1405 was initiate The test results indicated that the pump differential pressure was high and in the alert range. The system engineer increased the testing frequency for Pump 1A in accordance with procedural requirements. The test.was performed in a professional manner and was well controlle .3 Source Range Neutron Flux Channel Calibration (Unit 1)
On December 3, 1993, the inspector observed the performance of Plant Surveillance Procedure OPSP05-NI-0031, Revision 1, " Source Range Neutron Flux Channel I Calibration (N-0031)." The surveillance test was being performed by two instrumentation and controls technicians in-training, under the direct guidance of a certified technician. The performance.of this test was required on their qualification card as part of their certificatio When performing Step 7.15.10, the procedure instructed the technician to ,
remove the preamplifier cover; however, it did not inform the technician of the location of the preamplifier. The certified technician knew the location of the preamplifier that was several floors away in the electrical auxiliary building. The technician stated that he relied on his experience to know which preamplifier to adjust and where it was located. The procedure did not address the location nor the identification of the preamplifier. The preamplifier had an identification number affixed to the cover, but the procedure did not reflect this. The technicians were unable to verify that they were removing the correct cover. Failure to properly identify the
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component to be maintained has caused several wrong component events as documented in Section 3.4 of this repor l l
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-17-The inspector verified that proper authorization had been issued. The technicians in-training were knowledgeable of the system and had good communications. The responsible technician verified the results of the test throughout the performanc A maintenance feedback request was issued to identify and resolve the procedural deficiency. The inspector concluded that in light of the problems encountered with working on the wrong components at the plant, this was an example of inadequate guidance for technicians working in the fiel .4 Conclusions Overall, during the inspection period, surveillance testing was performed in an acceptable manne Procedures were considered adequate to perform the activity, but some confusing notes and cautions were presen In one example, plant labeling was inadequate to support the testing function. This could have resulted in additional wrong component events as discussed in Section ENGINEERING BACKLOG (RESTART ISSUE 5)
Both units were shut down in early February 1993, and remained shutdown as a result of numerous broad scope problems identified by the NRC and the license NRC Inspection Report 50-498/93-31; 50-499/93-31, issued on'0ctober 15, identified 16 restart issues that required resolution prior to the restart of Unit 1. In addition to these restart issues, a number of items related to these restart issues were identified. The purpose of this inspection was to determine the licensee's effectiveness in resolving Restart Issue 5, involving the backlog of engineering items, and to establish a basis for concluding that-this restart issue had been adequately resolved by the license The following sections document the review of specific items related to this issue that were statused concerning the manner in which the licensee had implemented their corrective actions. Some of these items were broad scoped and covered numerous licensee systems and programs. These items remained open pending further NRC inspection effort to completely reso.lve the item during future restart inspection .1 (Closed) Inspection Followup Item (IFI) 498:499/93031-81: Engineering Backlogs were Large. Poorly Tracked and not Well Manage Informational Data Bases were often inaccurate or not Current During the Diagnostic Evaluation Team inspection conducted at South Texas Project, the team determined that the engineering work backlog was large, rapidly increasing and ineffectively managed. The team found that the number of items in the backlog was increasing at a net rate of 428 items each calendar quarter. The engineering organization did not have an effective method to determine the size and composition of the engineering backlo _
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L-18-Licensee management established engineering review groups to identify open
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engineering action items which would not adversely affect plant material condition and which would not have any significant impact on safety-related ,
equipment or system operability. All engineering backlog items which did not meet these criteria were to be completed prior to restart. Open engineering-items reviewed included design change documents, preventive maintenance feedbacks, review of vendor submittals, document change notices, temporary modifications, nonconformance documents, plant impact assessments, and ~
prncedure upgrades. Action items were identified by the initial engineering screening as potential concerns. These concerns were then reviewed by operations and/or technical services personnel to identify any restart restraints or high priority item In addition to addressing restart restraints, management established short term goals for reducing the engineering backlog. These goals provided dedicated management oversight, established routine tracking and trending mechanisms, monitored performance at least weekly at all levels of supervision and management, established individual accountability for backlog items, ,
provided short term contractor resources, organized the engineering workload data bases, and reevaluated modifications within the backlog to ensure appropriate support for plant operation In July, an engineering work management system plan was prepare For the short term, a trending and backlog reduction program was put together to identify, categorize, and reduce backlogs. The long term plans included providing improved tracking and trending tools for improving management of the engineering workload, developing an integrated work management system to improve scheduling and resource utilization, and having all of the different workload items tracked on the same data bas This work management system was planned to be expanded to a permanent system to review the work plan for reducing emergent work-and reducing changing priorities, This work management system will be the responsibility of the engineering support division which was part of the new engineering organization. Management's expectations were to have the new work management system in place by early 1994. Currently, management trend charts, which give the status of all of the backlogs, were published weekly. The licensee stated
.that-these charts would continue to be used as a tool for managing the workloa In addition, the licensee stated that the current system for '
backlog and workload tracking would continue to be used until the new work management system was in plac The inspectors concluded that the licensee had greatly reduced the backlog and had improved the backlog tracking syste .2 (0 pen) IFI 498:499/93031-30: Additional Backlog Reduction Goals for Resumption of Power Operation Established for Engineering Evaluations In the Operational Readiness Plan, the licensee committed to demonstrate progress on completing a reduction of the backlog of general engineering items J
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-19-from a peak value of approximately 1400 items down to 600 items by the end of 1993. This category of backlog items, referred to as the general backlog, included operational experience reports, station problem reports, nondesign change plant change forms, document change notices, and design change-requests. Additionally, the backlog-reduction goal committed to having none .
of these documents greater than one year old without an engineering evaluation. This category of backlog items consisted of items that required engineering review to determine the applicability of generic issues, areas of concern as determined by field inspections, or analysis or general inquires of engineerin The design engineering department increased the number of personnel working in this area by seven in order to reduce the backlog. ' Additional contractor support was also used to reduce the backlog. The licensee defined the system engineer's workload which allowed more time for the system engineer to spend on reducing backlo On May 1, the total number of documents in the general backlog was in excess of 1400 items. This number includes the total workload in this area, including new items. The number of engineering evaluations greater than 1 year old was 81 on September 10, 1993. At the time of this inspection, the -
inspectors reviewed the licensee's tracking of these items and determined that the licensee had reduced the general backlog to below 600 items and still had 8 items greater than 1 year old without an engineering evaluatio The inspectors concluded that the licensee had made significant progress toward meeting the goals established in the South Texas Project Operational Readiness Plan. This item remained open until the licensee has met its commitments in this are .3 (Closed) IFI 498:499/93031-40: All Engineerinc P.acklon !tems will be Complete with the Exception of Items that do not Adversely Affect Plant Material Condition or have no Sinnificant..Safetv-Related Imnaci In the Operational Readiness Plan, the licensee committed to completing all engineering backlog items that adversely affected plant material condition as determined by the size and age of the backlog, and-items that had a significant impact on safety-related equipment or system operabilit The licensee reviewed the backlog of modifications, engineering change -
notices, and plant change forms. These items were reviewed to determine.which of them affected safe plant operation, equipment operability or caused additional operator workloads. The modifications, engineering change notices, and plant change forms were divided into two major groups which were restart and nonrestart issues. Those items that fell into the restart issue group were reviewed again by a system engineer. The system engineering department review also included issues which would improve the material condition of the pl ant .
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t-20-The results of the system engineering review were presented to the engineering
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backlog review board. This board was comprised of the Vice President of Nuclear Engineering, the Vice President of Nuclear Generation and various departmental representatives. The decision of the board placed each item into one of three categories: items that required installation for. restart; items that installation was to be performed as the outage schedule permitted; and items that were to be cancelled. Sixteen modifications and eight plant change forms were identified as plant restart restraints. As of October 29, the 16 modifications and eight plant change forms had been completed by the engineering organizatio The inspectors concluded that this related item had been completed by the license (0 pen) IFI 498:499/93031-41: Additional Backloo Reduction Goals
' In the Operational Readiness Plan, the licensee committed to reducing the number of undispositioned nonconforming plant change forms to less than 50 that were greater than 30 days old, and reducing the number of temporary modifications that were greater than 6 months old by 15 modification The inspectors reviewed the licensee's tracking of plant change forms and temporary modifications. On August 1, there were 129 plant change forms greater than 30 days old. At the time of this inspection, the licensee had reduced the number to 51 items. In addition, the licensee had not reduced the number of temporary modifications greater than 6 months old by 1 .
The inspectors concluded that the. licensee had made significant progress towards meeting the goals stated in the Operational Readiness Plan. However, :
this item remained open until the licensee had met its commitments in this ,
are .5 (0 pen) IFI 498:499/93031-42: Carr.yover items from Past Programs In .the Operational Readiness Plan, the licensee committed to either completing ,
the engineering work product or converting the item to a current work program ,
for various engineering review items that represented discontinued ~ engineering work programs. This category included requests for assistance, field change requests, and construction change package On June 1, the total number of carryover items was 129. At the time of this ,
inspection, the number had been reduced to eight item ;
i The inspectors concluded that the licensee had made significant progress towards meeting their goals. However, this item remained open until the licensee had met its commitments in this are l
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- 6.6 '(Closed) IFI 498:499/93031-52: Elimination of Temporary Flow Instruments or Temporary Pressure Gauqes in Surveillance Tests q l
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e-21-In the Operational Readiness Plan, the licensee stated that design changes or plant change forms had been initiated to eliminate the use of temporary flows instruments or temporary pressure gauges in surveillance tests for a number of systems. The systems affected were essential chilled water, high head safety injection, spent fuel pool cooling, and screen wash booster pump The inspectors reviewed Plant Change Forms 176278-A, 176279-A, and 176280-A, all dated August 20, which were prepared for the high head safety injection pumps for the three Unit 1 trains. The plant change forms stated that the flow element accuracies did not meet the accuracy requirement of ASME Section XI. The licensee revised the scaling documents and recalibrated the flow elements. The engineering work associated with these three documents were completed on October 1 The inspectors reviewed Plant Change Form 178496-A dated August 12, which was prepared to add essential cooling water screen wash booster pump suction pressure indicators in the three Unit 1 trains. The work was completed as of December 3, 199 The inspectors reviewed Plant Change Form 310424-A dated June 21, which stated that the operators did not have proper indication to determine when cooling to the spent fuel pool was lost. The recommended action was to add flow switches to comwnent cooling water to the spent fuel pool and spent fuel pool cooling pump systems. This modification was scheduled for February 23, 1994. The licensee stated that they wanted to have all of the hot fuel out of the pool prior to performing the modification. In addition, the licensee stated that the plant change form was not a restart restrain The inspectors reviewed Plant Change Forms 176271-A, 176272-A, and.176273-A, dated June 22, which stated that the essential chilled water Annubar flow elements used to measure flow from the component cooling water heat exchangers did not meet the ASME Section XI accuracy requirements. The licensee revised the scaling for the instruments which was completed October 11.for the three Unit 1 trains. The inspectors concluded that the *licensee had met the goals stated in the Operational Readiness Pla .7 (Closed) IFI 498:499/93031-31: Additional Backloo Reduction Goals In the Operational Readiness Plan, the licensee committed to updating .
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311 vendor documents with five or more amendments which had been identified as impacts on operations and maintenance performance, updating key control room -
drawings, insuring that no master parts list change forms were open greater than 60 days, and reducing the backlog of preventive maintenance and service request history reviews from 6100 to 200 items by the.end of 199 The inspectors reviewed the licensee's tracking of the above items and found:
the 311 vendor documents had been updated; all key control room drawings were upgraded; there were no master parts list change forms open greater than 60 days; and the preventive maintenance and service request history backlogs had been reduced to under 200 items by November 1993. However, these history
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-22-r backlogs had increased to 251 items caused by a sudden influx of packages from the maintenance organization. The inspector noted that approximately 2100 in-process work d9cument items could at any time be received from the maintenance organization. Effective December 13, 1993, only history items
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over 2 weeks old we n reported. There were 23 items in this category. The licensee felt that the currant backlog'was within a manageable working leve The inspectors concluded that the licensee had met their established goal .
6.8 (Closed) Violation 498:499/93008-02: The Licensee Failed to Acceptably Investigate an April 1989 Valve Failure. Correct the Condition in a >
Timely Manner, Determine the Root Cause of the Event, and Take Actions to Prevent Recurrence. Consequently, the Same Valve Failed under Similar Circumstances in February 199 In April and November 1989, the licensee identified a significant condition
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adverse to quality related to an inoperable motor actuator on Unit I safety-related Valve SI-MOV-0031A but did not replace the actuator until '
October 1990. Further, .the licensee did not determine the cause of the failure, take action to preclude recurrence, nor document and report the -
condition to appropriate levels of management until the motor failed again :
under similar circumstances on February 9, 199 W e licensee's corrective actions to the most recent event included: ,
- Significantly improving the operability determination process since occurrence of the original event as demonstrated by the correct. rbot cause determination of the February 9, 1993, failure. Also, enhancing the operability tracking log process .to include pre-written, standardized forms for tracking operability of equipment as required by Technical Specification q
- Reviewing outstanding operational tracking log entries and work documents on Unit 1 to ensure current operability determinations were adequat . Reviewing the historical operational tracking log entries and key safety-related service requests to determine if historical operability or reportability issues existe '
Upgrading the program used to analyze and trend equipment histor '
. Conducting training to increase personnel awareness of the definition of nonconforming conditions and the necessity of prompt corrective actio * Revising appropriate plant procedures to include specific examples of nonconforming conditions and specific instructions for dealing with j forms that document nonconforming condition . . . _ _ _ . _ _ _ - _ . - - . .
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-23-The inspectors reviewed the licensee's associated corrective action documentatio The inspectors determined that the licensee's actions to address this issue were adequat .9 (0 pen) IFI 498:499/93031-08: Ineffective Corrective and Weak Preventive Maintenance Significantly Contributed to Poor Equipment Performance
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6. Motor-0perated Valve Actuator Windings
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This specific line item was closed for Restart Issue 5 based on the licensee's corrective action described in Section 6.8, addressing Violation 93008-02 in this repor ,
6.9.2 Qualified Display Processing System Fasteners
In August 1992, the licensee discovered that seismic hold down screws in the Unit 1 qualified display processing system card racks were missin i Maintenance workers had failed to reinstall the screws following work in the system cabinets during the recent Unit I refueling outage. These screws retained the slide-out chassis into the associated cabinets and contributed to the seismic qualification of the system. Without adequate retaining screws, ,
operability of the associated components could not be insured during and after ~
a postulated seismic even On January 4, 1993, a service request was written concerning the missing i seismic hold down screws. Although the shift supervisor requested an ,
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engineering evaluation, called a conditional release authorization, to determine if the system would perform its design function under all analyzed conditions, neither the system engineer nor the shift supervisor recognized '
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the potential operability issue. The service request was then inadvertently filed instead of being sent to technical support engineering for the i operability evaluatio On April 28, during a review of the service request package, the failure to complete the conditional release authorization was identified. A preliminary evaluation determined that portions of the qualified display processing system ->
were not in a seismically analyzed condition with the screws missing, and those portions-were declared inoperabl The licensee restored the system to the as-designed condition and assessed _th'e ,
impact of the missing screws. To r.inimize the potential for recurrence, the licensee's corrective actions-included: ,
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- Walking down similar components to determine if other potential operability issues existed because of missing screw ,
- Reviewing open service requests to determine if other nonconformances that could potentially affect operability had been identified and -
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- Training the operations work control group personnel that screened new service requests on equipment qualification requirements to enable them to properly identify conditions similar to this even . Issuing a maintenance department training bulletin to address configuration management as it related to maintenance work practice * Enhancing the process for obtaining conditional release authorizations to include specific processing requirements and to clearly define process accountabilit * Training engineering, operations, and maintenance personnel on equipment qualification requirements for system operabilit The inspectors reviewed the licensee's associated corrective action documentation and concluded that the licensee addressed the issue adequatel This specific line item was closed for Restart Issue 5, based on the licensee's corrective actio . Increased Inservice Testing Frequency This specific line item was closed for Restart Issue 5 based on the licensee's corrective action described in Section 6.19 (IFI 498;499/92035-01) of this repor Based on these reviews, IFI 498;499/93031-08 was closed with respect to Restart Issue 5. However, based on its generic nature, this item remained open pending further NRC restart issue inspection .10 (Closed) IF1 498:499/93031-19: Configuration Control Weaknesses which Adversely A,ffected Safety-Related Plant Equipment, were Noted in Several Instances, such as Molded Case Circuit Breakers. Standby Diesel Generators, and Environmental Qualification of Motor-Operated Valve Actuators 6.10.1 Diesel Engine Rocker Arm Installation This item was reviewed and documented in NRC Inspection Report 50-498/93-44; 50-499/93-44. Therefore, this specific line item was closed for Restart ,
Issue 5 based on the licensee's corrective action documented in that repor .10.2 Trip Settings for Molded Case Circuit Breakers The electrical setpoint index for molded case circuit breakers was not properly understood or implemented in the field resulting in operability concerns. While performing maintenance on molded case circuit breakers, the technicians discovered that magnetic trip settings were adjusted using the electrical penetration test point calculations for permissible currents rather than trip values obtained from the index. The licensee later determined that l
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-25-these instantaneous trip settings were improperly adjusted for approximately 30 breakers in both units. The licensee found operability concerns with 10 breakers powering motor-operated valve actuators such as containment and safety injection accumulator isolation valves. This condition may have existed since the original plant startup. Although the index contained appropriate criteria, the licensee had not prepared detailed work or procedural instructions for craft personnel to use in interpreting or scaling the index guidance.
l The licensee attributed the problem to a lack of clarity in the instructions for setting the magnetic adjustable elements leading to inconsistent 4 application of setpoint criteria. Contributing to the deficiency was training material that was also unclear in this area. Training materials were upgraded and training provided. In addition, the electrical setpoint index and
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affected test procedures have t 'n:- *evised to provide clarification for setting of these circuit breaker .
l The licensee's corrective actions included:
+ analyzing and reseting affected breakers,
+ revising the test procedure to clarify the trip setpoint methodology,
+ conducting training on the test methodology, and
+ revising the electrical setpoint index to clarify trip setting criteria.
The inspectors reviewed the licensee's associated corrective action documentation. The inspectors determined that the licensee's actions to address this issue were adequat Based on these corrective actions, this specific line item was closed for Restart Issue .10.3 Motor-0perated Valve Actuator "T" Drains
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Based on the licensee's corrective action for Unresolved Item 499/93019-07,
" Failure to Maintain the Motor Operator for the Unit 2 RHR B Train Suction Valve in a Configuration Supported by Test Results," documented in NRC Inspection Report 50-498/93-35; 50-499/93-35, this specific line item was closed .%r % start Issue .10.4 Review of Unincorporated Vendor Drawing Amendments Based on the licensee's corrective action for IFI 498;499/93031-31 described in Section 6.7 of this report and the above addressed item closure, this specific line item was closed for this engineering backlog Restart Issue . _ _ _ _ _ _ _ _ _ . ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
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Ifl 498;499/93031-19 was opened to track four specific weaknesses in configuration control of safety-related plant equipment. These four specific line items were addressed and closed as documented in Sections 6.10.1 - 6.1 '
of this repor .11 1 Closed) Violation 498:499/93008-04: The Licensee Failed to Make a ,
Proper Operability Determination on February 2. 1993. and Failed to Take immediate Corrective Actions to Address the Overtorque Problem of the RHR Suction isolation Valves
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On February 2,1993, the licensee determined that five Unit 1 RHR system suction isolation motor-operated valve actuators had incurred torque loadings of up to 253 percent of the actuator qualified limit for up to 50 cycles. A t condition adverse to quality was identified, but engineering personnel failed
to identify the full scope of the deficiency and take adequate corrective action. Specifically, the licensee concluded that the valves were operable '
based on valve internal inspections conducted during the previous outage, that recorded excessive wear on the worm gear, a component vulnerable to the effects of high torque. The licensee' developed no justification or basis ,
consistent with the recommendations of the actuator vendor or information published by or for the users of motor-operated valve actuators in the nuclear .
power industry for the continued application of torque values in excess of the i qualified limi The licensee's corrective actions included: :
- Reworking the actuators as required to achieve acceptable output torque values while still achieving greater than minimum required stem thrus * Performing a detailed reportabity review and impact evaluation to assess the ability of the actuators to meet system design requirements while exceeding allowable maximum torque value * Revising the test procedures to require a detailed analysis of the test I data, allowing a firm and complete determination of test parameter acceptability prior to a declaration of operabilit t
- Reviewing historical actuator test data and evaluations and verifying '
the absence of any condition that would impact the operability of an .
If such a condition was identified or the absence of such
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! a condition was indeterminate, the licensee initiated the appropriate corrective action to assure a valid declaration of operabilit The inspectors reviewed the licensee's associated corrective action documentation. The inspectors determined that the licensee's actions to address this issue were adequat ,
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t-27-6.12 (Closed) IFI 498:499/93031-77: Torque Measurements and Computations ,
Associated with Testing of Motor-Operated Valve Actuators were not !
Evaluated to Verify Valve Operability. Other Valve Operability / ;
Reliability Issues Existed ;
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Engineering analysis of data from static testing of the 1RH-MOV-0060 and 1RH-MOV-0061 valve actuators revealed an overtorque condition on five out of ,
the six valves. This condition was discovered after the valves had been "
declared operable. The valve actuators were tested in late October and early
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November 1992. Determination that the over torque condition existed did not 3 occur until February 199 This item was closed based on the licensee's corrective action described in Section 6.11, on Violation 498;499/93008-04, of this repor ,
6.13 (Closed) IFI 498:499/93031-64: The Overall Ability of Nuclear Engineering Management to Manage the Required Work 1.oad has been Enhanced through Assignment of a New Vice President. Nuclear i Engineering, with Further Improvement Following a Comprehensive i Realignment of the Engineering Organization to be Completed Prior to Resumption of Power Operation The reorganization of the nuclear engineering group was implemented effective i December 6, 1993. A nuclear engineering reorganization transition plan was ,
developed to identify the new responsibilities and the activities necessary to implement the plan. This also identified procedures which will be revised at A a later date and identified which organizations or groups were responsible for procedures interfac Completion of the nuclear engineering reorganization plan of action was l ongoing during this inspection period. Several of the plan items were 1
complete with all but the engineering work schedule projected to be complete I by the end of 199 .
The inspectors reviewed the nuclear engineering reorganization transition plan and schedule status. The inspectors concluded that the licensee's .
implementation status of the plan of action was sufficiently implemented or '
scheduled for completion to close this ite :
6.14 (0 pen) IFI 498:499/93031-18: The Engineering Departments gave Weak Support in Resolvino Plant Problem The Root Cause Analyses and a Resulting Corrective Actions were Often Ineffective in Preventing ;
Repetitive Equisment Problems (Generic Issues) ;
io improve qualitt, depth, and consistency of root caust analyses, the engineering department contracted the services of an industry expert who specialized in roct cause analysis. They plan to provide training to.a multi- 1 discipline group of South Texas Project engineers in 1994. Further, the :
station problem report screening group and problem review group both irclude i engineering representatives, accordingly increasing engineering support and j l
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i-28-communications among organizations. Additionally, the recent closure of a number of equipment issues related to this IFI and others, demonstrated .
improvement in this area. Revision 2, to Plant General !
Procedure OPGP03-ZX-0002, " Corrective Action Program," effective December 10, 1993, incorporated several enhanceTent The inspectors concluded that the licensee's actions had shown significant improvement related to engineering backlog generic issue IFI 498;499/93031-18 generic issues were closed for Restart Issue 5. Review of this item continued in Section 6.15 of this repor .15 (0 pen) IFI 498:499/93031-18: The Engineerina Departments gave Weak ,
Support in Resolving Plant Problems. The Root Cause Analyses and .
Resultina Corrective Actions were Often Ineffective in Preventinq !
Repetitive Equipment Problems (Specific Issues)
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6.1 Repeated Failures of Toxic Gas Monitors l The root cause analysis and accompanying corrective actions were ineffective }
in preventing repeated failures of the toxic gas monitors and containment ventilation isolation system. Since 1987, 28 toxic gas monitor events occurred, including 6 during 1991 through 1992. Similarly, there.were several repeat occurrences involving spurious actuations of the containment ,
ventilation isolation system, including four during 1991 through 199 These events were associated with the infrared detectors that have since been [
replaced with three, state-of-the-art mass spectrometers in accordance with Plant Modifications 91015 (Unit 1) and 91016 (Unit 2). The high toxic gas ,
actuation signal logic was changed from 1-out-of-2 to '2-out-of-3 logic and the loss of power / malfunction logic was changed from 2-out-of-2 to 2-out-of-3 logic. Additionally, a three-position switch has been installed to I provide a positive trip function. Surge suppression devices and isolation transformers to filter noise and provide a higher quality sine wave to the analyzers have also been added. A universal disturbance analyzer was installed under Temporary Modification T1-HE-93-013 to monitor the effectiveness of the isolation transformer and surge suppressors throughout the restart power ascension pla ,
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The inspectors reviewed the licensee's associated corrective action documentation and determined that the licensee's actions were adequate to address this issu '
6.15.2 Performance Problems with . Solenoid-0perated Valves This specific line item was closed for Restart Issue 5. The licensee's corrective actions for these problems were described in Sections 6.16 and 6.17 *
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-29-6.15.3 Qualified Display Processing System Fasteners This specific line item was closed for Restart Issue 5 based on the licensee's corrective actions described in Section 6.9.2, addressing IFI 498;499/93031-08, of this repor .15.4 Circuit Breaker Corrective Action Corrective actions for numerous safety-related and nonsafety-related circuit breaker problems were not aggressive or complete. The licensee evaluated each ,
breaker failure and took corrective actions for safety-related breakers. Many of these actions were incomplete. Furthermore, the licensee was slow in resolving problems and taking corrective actions for many nonsafety-related breaker r Statica Problem Report 920176 was written in January 1992 to address problems experienced with ASEA Brown Boveri Model LK breakers and lack of vendor technical bulletin updates for these components. The circuit breaker steering >
committet was formed in response to this and other circuit breaker problems ,
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experienced at the South Texas Project. Initiatives pursued by the. breaker steering committee included modifications to upgrade selected load center circuit breakers and the development of a comprehensive circuit breaker overhaul program for nonsafety-related 480V load center circuit breaker ;
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I In March 1992, the circuit breaker overhaul lubrication program was initiated by the maintenance department. At this time, maintenance technicians had completed the overhaul of nearly all the 13.8 KV breakers. The technicians
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had begun the overhaul of the 4160 volt nonsafety-related breaker :e overhaul of the 4160 volt safety-related breakers were completed f. snit I and in progress for Unit 2 and projected to be complete in February 199 The inspectors review of the licensee's progress in developing and .
implementing resolutions to these identified problems and taking corrective actions had shown a significant improvemen ,
Based on the closure of the above described specific line items, IFI 498;499/93031-18 was closed with respect to Restart Issue 5. However, based on its generic nature, this item remained open pending further NRC -l Restart Issue inspection ,
6.16 (Closed) IFI 498:499/93031-48: The Status of the Solenoid-Operated Valve Issues will be Evaluated as Part of the Assessment Process The solenoid-operated valve task force has formulated a plan of action to address valve issues identified in Generic Letter 91-015 and NUREG 1275. The-task force had assessed that the engineering, operations, and maintenance organizations did not have a complete understanding of solenoid-operated valve design characteristics, failure mechanisms, proper operational modes,. and correct maintenance and surveillance testing practices. Implementation of the plan.of action was designed to: establish this knowledge base via engineering
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design and application review of each valve; review and revise maintenance procedures; and develop a solenoid-operated valve data base. .An engineering review of all Target Rock brand valves will be performed by January 1, 199 f'
The inspectors reviewed the licensee's associated documentation and concluded that the licensee's task force had made progress in statusing the '
solenoid-operating valve issues. Support of the task force's plan of action was vital for ensuring that the problems encountered with the valves were
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resolved. The inspectors found those actions to be acceptabl .
6.17 (Closed) LER 499/92-004. Revision 1: Entry into Technical Specification 3.0.3 based on Containment Isolation Valves Failing to Close ,
The licensee declared an Unusual Event and a plant shutdown was commenced because of an entry into Technical Specification 3.0.3 when the action statement of Technical Specification 3.6.3 could no longer be met because both containment isolation valves were declared inoperable and could not be
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verified to be in the closed positio The Train C steam generator bulk water Isolation Valves 2FV-4187 and 2FV-4187A failed to close on demand and on removal of power to the valves. The valves were initially opened to obtain water samples during work on Train C steam generator bulk water sample line. The cause of the Containment Isolation Valve FV-4187A failure was determined to be the inadequate application of the Target Rock brand valve. The design of this type of valve makes them susceptible to binding from suspended materials; and the blowdown sample line,
- by design, would always have some-level of. suspended material. The cause of .
failure of Isolation Valve FV-4187 was attributed to both a low differential pressure across the valve and limit switch misalignmen The licensee's corrective actions included:
- Creating administrative controls for operators to maintain containment integrit * Submitting a Technical Specification change to 3.6.3 to properly *
address those containment penetrations that meet the requirements of General Design Criteria 5 '
- Installing a temporary modification in Unit 1 to provide for manual bulk water sampling capability. The steam generator bulk water sampling solenoid-operated valves were de-energized in the ,
closed position, and a bypass stainless steel tubing from the !
existing upstream drain valves to sample tubing was installed around these valves. The temporary modification was scheduled to be installed in Unit 2 during the current outag l
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- Evaluating the design for these valves and determining the different options to make a permanent corrective actio * Addressing the generic issues related to solenoid-operr.ed valve applications as part of the task force's action pla ,
The inspector reviewed the licensee's records and verified that the corrective :
actions had been completed. The licensee has included, as part of their Business Plan, approved Modifications 93055 and 93056 authorizing engineering evaluations to determine an optimum valve design in 1994. Following the ,
design modification, the steam generator bulk water sampling solenoid-operated ;
valves will be replaced during the 1995 refueling outage .18 (Closed) LER 498/92-020: Toxic Gas Monitor Channel Found in the '
Nontripped Condition Contrary to Technical Specifications
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On December 9, 1992, and again on December 12, 1992, operators discovered that the Toxic Gas Monitor XE-9326 channel was not in the tripped condition as i required by Technical Specification 3.3.3.7 while performing control board wal kdowns. Toxic Gas Monitor XE-9326 had been declared inoperable since "
November 23, 1993, based on a noisy power supply, and the channel was tripped as required on November 28, 1993. The cause of this event was a less than adequate design of the toxic gas monitoring system. .There was no means to positively place the monitors in tri As part of the licensee's corrective actions, a revision to a design change was developed and issued to replace the existing 2-position handreitch in .
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Local Control Panel ZLP-1034 with a 3-position handswitch providing a positive
" trip" function. To address generic implications of this event, a contractor performed a complete design review. A failure modes and effects study was conducted. The contractor concluded that no additional changes were require The inspectors reviewed the licensee's corrective actions and found no ,
discrepancie l 6.19 IClosed) IFI 498:499/92035-01: Licensee Actions Relative to Power-Operated Valves on Increased Test Frecuency The number of components on the increased frequency list was being .ucked.and trended on a weekly basis. These trends were being reported to management an,d were discussed in the plan of the day meeting. The number of components had been reduced from 38 in May'1993, to 26 as of October 29. An evaluation of :
the historical and current test results was performed to assess whether the l condition of the components can support a decreased testing frequenc )
i The plant engineering department prepared an evaluation guideline for removing l valves from increased testing frequency for system engineers'. This wcs 1 documented in Field Change 93-1719 and incorporated into
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l Procedure OPGP03-ZE-0021, Revision 6, " Inservice Testing Program for Valves." l l
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It was management's intent to reduce the number of components on increased frequency testing to O prior to Unit I restar If components still required an increased testing frequency, an evaluation would be performed to determine -
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the operational impact prior to plant restart, consistent with the Operational Readiness Plan, j ihe increased frequency testing had received heightened visibility by management, and the engineering department was given full ownership and -
accountability for the progra The inspectors noted that the tracking, trending, and evaluation of the number of components on increased frequency met managements expectations and would -
aid in decreasing the burden on operators to accomplish testin .20 (Closed) IFI 498:499/93031-49: Management will Review the Number of Components on Increased Surveillance Testing Frequency to Ensure that the Burden on Operations and Maintenance Relating to the Testing of These Components will not Adversely Affect the Safe Operation of the Plant This item was closed based on the licensee's corrective actions described in '
Section 6.19, concerning IFI 498;499/92035-01, of this repor .21 (Closed) Violation 499/93015-01: The Licensee used Inappropriate Reference Values for Differential Pressure during Surveillance Testing of the RHR Pump 2A, Resulting in Incorrectly Declaring the Pump Operable and Incorrectly Returning it to Service /
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On January 29, 1993, plant engineering department personnel generated a field change to the RHR Pump 2A inservice test, to add a means to control RHR pressure during inservice testing to prevent a challenge to the relief valve This field change included a RHR pump data sheet which contained pump ;
differential pressures values from a February 11, 1989, reference value tes This inappropriately changed the RHR Pump 2A differential pressure reference value test data. The appropriate reference value data should have been from a September 3, 1992 tes The inspectors reviewed the licensee's corrective actions and verified that-the correct reference values were incorporated.in the procedure. Training has
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been given to all responsible personnel involving preparation of procedure ,
changes, along with the self-verification progra '
6.22 Assessment of Management's Receptiveness to Identifying and Correcting Plant Problems Management support was evident throughout this area of inspection. The licensee's actions taken have included: reactive measures for previously identified problems; establishing programs that when fully implemented should improve engineering quality; and, initiation of backlog reduction and control -e measures. These positive actions were indicative of management-driven
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. e-33-initiatives that should result in improved engineering backlog reduction and in overall control of the engineering workload. As the implementation of newly established programs progresses, the opportunity to show improved engineering support in identifying and correcting plant problems in a timely manner shoult' imprcv .23 Conclusion The engineering department personnel performed a good job on closing the specific items addressed above. The recent implementation of engineering programs should help reduce the engineering backlog and improve backlog control measures. Additional inspection was deemed necessary to fully evaluate the licensee's readiness to restart, based on the area of engineering backlog and work loads. Therefore, Restart Issue 5, "The Outstanding Design Modification, Temporary Modifications, and other Engineering Backlog items, including the Licensee's Review of These For Issues Affecting Equipment Operability, Safe Plant Operation, and Operator Work-Arounds," remained ope FIRE PREVENTION AND PROTECTION (64704).
7.1 Background During a Diagnostic Evaluation Team inspection conducted March 29 through April 30, 1993, by the NRC, several issues were identified that raised questions about the adequacy of fire prevention and protection.at the South Texas Project. The major concerns were: the condition of deteriorated fire barrier penetration seals; control of transient combustibles; operator ,
distraction by the fire alarm and computer systems; fire brigade leaders'
knowledge of safe shutdown systems; and a large maintenance backlog on the fire protection systems. The licensee responded and initiated corrective actions to address the fire protection related concerns for Unit 1 and items common to both unit The inspectors performed a followup inspection reported in NRC Inspection ';
Report 50-498/93-37; 50-499/93-37 to assess the adequacy of fire protection and prevention of Unit 1 for restart. That report indicated that most of the :
corrective actions to address the identified concerns had been initiated and, in some cases, fully implemented for Unit I and systems common to both unit The only issue requiring further licensee action was the improvement of the ,
material condition .of Unit I fire protection systems ano those common to both units by addressing the excessive maintenance backlog. During this inspection ,
period, the inspectors assessed the licensee's actions to reduce this backlog !
and assure the adequacy of fire detection and suppression system j
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7.2 Reduction of Fire Protection System Maintenance Backlog i i
During the previous followup inspection documented in NRC Inspection l Report 50-498/93-37; 50-499/93-37, the inspectors determined the number of i specific tasks that needed to be addressed to complete all needed repair on i the Unit 1 fire protection systems and those common to both units. This
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baseline was established on October 12, 1993, for the fire detection and alarm system and fire suppression systems. The original scope of work included .
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133 fire suppression items and 38 fire detection and alarm system items that needed to be addressed to eliminate the backlo The licensee obtained contracted assistance to help in the bae.klog reduction .'
effort. The contractor personnel were placed under an HL&P maintenance supervisor and their effort was dedicated to the replacement and repair of mechanical equipment, mainly within the Unit 1 power block. A special group -
of HL&P craft personnel was dedicated to the restoration of fire suppression .
system diesel engines and pumps. Facilities group maintenance personnel were ,
assigned the majority of the mechanical work outside the power block, excluding pumps and diesel Plant computer maintenance personnel were ,
assigned to perform the instrument and controls related repair and replacement :
of the fire detection and alarm syste '
During this inspection period, inspectors determined that the licensee had identified more work to be performed on both systems. The review and repair process had identified an additional 34 work items for the fire suppression .
system. A total of 48 new items had been added to the scope of work for the J
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fire detection and alarm system. This represented an increase of over '
100 percent of the original nrmber of items. The additional discrepancies had been identified in the course of working on the original list of items and by j plant personnel continuing the alarm trending program. These items had been added to the original scope and management's goal was to close all items prior to the restart of Unit The inspectors determined the progress as of December 15, 1993. The licensee .
had completM the work on all but 15 of the fire detection and alarm system work items The original baseline list of 38 items was totally closed ou ..'
Of the 15 . ems left, 6 represented modifications, and the licensee planned to implemer,t 5 of the modifications prior to Unit I restart. The one modification that would not be implemented.was the complete replacement of the !
Unit i fire alarm and computer system. About 80 percent of the fire detection '
and alarm system list had been completed. According to the maintenance tracking system, approximately 60 percent of the total of fire suppression ;
system items had been worked to completio I The percentages above did not accurately reflect the amount of work completed or remaining. Some of the work items were complex and difficult while others'
were relatively simple. The inspectors held discussions with the fire ,
protection program supervisor, applicable system engineers, and maintenance 'I supervisors to gain insights about the actual amount of work completed. These 3 discussions and a review of the work remaining provided indication that a ;
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majority of the complex and lengthy work items had been completed. Also, '
there had been no rework required for the significant amount of work performed by the contractor personnel. From these discussions and reviews, the inspectors determined that 80 to 85 percent of the total required effort had i been completed to disposition all the hardware deficiencies in the backlo Licensee representatives stated that it was planned to cisposition the l
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-35-remaining work items and address any emerging work items prior to Unit I restar These representatives also stated that at some time in the near future, they would reinvoke the normal work prioritization system to address the remaining or emerging work. Maintenance supervisors and system engineers expressed confidence in the program's ability to address all currently remaining work items prior to Unit I restar .3 Conclusions The inspectors determined that licensee management had performed effectively in addressing the material condition cf the reviewed fire protection system The current effort was ahead of schec'ule and work items were being completed '
at a faster rate than expected. Contractor personnel were performing better than original expectations as there hac not been any required rework. The licensee's identification of additional system deficiencies was considered a strength. Based on this inspection and the review performed and documented in NRC Inspection Report 50-498/93-37; 50-499/93-37, the inspectors concluded-that the status of the fire protection system backlog should not be an issue affecting the scheduled restart of bnit 2. The refore, Restart Issue 8,
" Adequacy of Fire Protection Computers and C tware, the Licensee's Success in Reducing the Number of Spurious Fire. Protection System Alarms, and other Fire Protection Hardware Problems," identified in NRC Inspection Report 50-498/93-31; 50-499/93-31, was considered resolve .4 Status of Items Related to Restart Issues (92701)
The following items related to Restart Issue 8 were addressed concerning the manner that the licensee had resolved-the issue within the scope of fire protection and prevention. One of these items was broad scoped and covered numerous licensee systems or programs. This item remained open pending further NRC inspection effort to completely resolve the items during future restart inspection . (0 pen) IFI 498;499/93031-02: Operators were Significantly Affected by Degraded Plant Equipment, Including Equipment Workarounds and the Administrative Burdens Associated with the High Rate of Removal and Return of Equipment to Service During this inspection period, the licensee had implemented a significant portion of the corrective actions that had been identified as.needed to improve the material condition of the fire detection and suppression system Licensee action described in Section 7.1 provides the basis for this determinatio Based on this review, IFI 498;499/93031-02 was closed with respect to Restart Issue 8. However, based on its generic nature, this item remained open pending further restart issue inspection ,
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7. (Closed) IFI 498;499/93031-17: The Licensee did not Resolve Several Chronic Fire Protection Issues in a Timely Manner. The Issues Included Excessive Shrinkage of Penetration Seals, an Unreliable Fire Alarm System, a large Backlog of Service Requests on Fire Protection Systems, -
and Inadequate Control of Transient Combustibles in the Plant
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Inspectors reported in NRC Inspection Report 50-498/93-37; 50-499/93-37 that the licensee had adequately addressed the problems of penetration seal-shrinkage, the unreliable fire alarm system, and control of transient combustible Licensee actions described in Section 7.2 of this report provide substantiating details on the licensees satisfactory effort to address the large backlog of service requests on the fire protection syste . (Closed) IFI 498;499/93031-22: The Licensee did not Resolve Numerous Fire Protection Issues in a Timely Manner. The Issues Included Excessive Shrinkage of Penetration Seals, an Unreliable Fire Alarm System, a Large Backlog of Service Requests on Fire Protection Systems, and Inadequate Control of Transient Combustibles in the Plant These identical issues were addressed in Section 7.4.2 of this repor E 7. (Closed) IFI 498;499/93031-75: The NRC will Assess Action to Resolve- -
Fire Protection Deficiencies at STPEGS. These Deficiencies Included:
(1) Fire Protection Computer Alarm System and Operator Training on the -i System; (2) a large Backlog of Service Requests on Fire Protection '
Systems; (3) Control of Transient Combustibles in the Plant; and (4) Fire Brigade Leader Qualifications and the Impact on Operatis s Staffing Inspectors reported in NRC Inspection Report 50-498/93-37; 50-499/93-37 that the licensee had adequately addressed the problems of the improvement of unreliable fire alarm system and related training of operators, control of transient combustibles, and the fire brigade leader qualifications and his ,
impact on staffing. Licensee actions described in Section 7.2 of this report :
provide substantiating details on the licensee's satisfactory effort to address the large backlog of service requests on the fire protection system for Unit 1 and common system SYSTEM CERTIFICATION REVIEW ,
) Background During the Diagnostic Evaluation Team inspection documented in an NRC '
Evaluation Report dated June 10, 1993, the team identified that operators were
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significantly affected by degraded plant equipment, including equipment workarounds and the administrative burden associated with the high rate of removal and return of equipment to service. ' Additionally, weaknesses in the .
maintenance and engineering organization had created large backlogs of work in each organization. The backlogs caused concern for the overall readiness' and operability of safety-related systems to support plant operation . .. --
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As a result of these findings, the licensee developed the system certification program to demonstrate the operational readiness of the plant by comparing the material readiness of the plant systems or components to objectives and measurable criteria. This process was committed to in the licensee's Operational Readiness Pla ,
8.2 S_ystem Acceptance Review
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The inspector reviewed Station Procedure OTGP03-ZA-0006, Revision 0, " System Acceptance." Under this procedure, system engineers conducted final reviews of critical systems to provide for the acceptance of the system to support-plant restar This review used, as a starting point, the system readiness packages developed under Station Procedure OTGP03-ZA-0005, Revision 0, " System Readiness." The reviews conducted under that procedure were inspected as-documented in NRC Inspection Report 50-498/93-36; 50-499/93-3 In addition to the review of all work documents generated since the approval of the system readiness review package, the system engineers performed a :
comprehensive system walkdown. These walkdowns were performed with a licensed operator and a maintenance supervisor in attendance, and equally responsible for +he quality of the walkdow Tia inspectors observed the walkdown team performing the in-field review of ;
tne spent fuel pool cooling system. The team members independently made observations which were later combined and documented in the system walkdown report. The inspectors identified several small items that were.not identified by the team. These included a cable tray with a bent cover, a small area of flaking rust on a pipe support, two inoperative light bulbs, and '
coatings on an electrical penetration cracking and peeling. Although these items did not appear to affect system integrity or operability, they did meet the attributes listed in Station Procedure OTGP03-ZA-0006 as typically needing to be documented on the system walkdown inspection report form. Additionally, the inspectors noted that some system components were not thoroughly' inspected by all team member After discussion with plant management on these findings, a memorandum was issued on November 29, 1993, to reiterate the standards and expectations of management with regard to the system certification walkdowns. This document addressed the concerns of the inspector. Future observations in this area ,
determined that the concerns had been correcte On December 1,1993, the inspecti r observed the walkdown of RHR System I The system engineer appeared to be knowledgeable of his system; and the walkdown team appeared to have the correct sensitivity and threshold for identifying problems in material condition, equipment deficiencies, and poor housekeeping. These items were properly documented in the system walkdown inspection repor The inspector noted that on several occasions the walkdown team recommended that boric acid be removed from a plant component. Although no evidence of
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-38-current leakage was present, plant management should be cognizant of these items and evaluate the components for leak tightness during plant restar During a tour of the pump room, the inspector identified that a leak sealant clamp had been installed on the pump discharge flange and that numerous injection ports were spaced evenly around the outside diameter. Boric acid crystals had collected around the bottom of the clamp and on the floor belo The acid appeared to be damp and was apparently an active lea Following the walkdown, the inspector reviewed the system walkdown' report prepared by the team. The report mentioned that the leak sealant clamp was installed and that the boric acid crystals should be cleaned off to help identify the extent of any remaining leakage. The walkdown package did not address the clamp further. However, on December 10, 1993, the system engineer wrote a Station Problem Report (SPR 933447), which stated that no document existed to remove the clamp and return the pump discharge flange to its original condition. The clamp was originally installed under Service Request RH-175395 which implemented Plant Change Form 175395- The inspector reviewed Service Request RH-175395 and noted that the clamp had been injected twice and still continued to leak. Additionally, the wor instructions under this service request instructed the workers to " peen as necessary." This statement allowed workers to utilize their.own judgement in determining the need for an extent of mechanical peening required along.the split-line between the clamp and the flang The inspector discussed this condition with plant management and called their attention to NRC Information Notice 93-90, "Unisolable Reactor Coolant System Leak Following Repeated Application of Leak Sealant." Following a. review of the installation and conditions, plant personnel were instructed to remove the clamp and return the flange to its original condition prior to restar Following the completion of the licensee's system certification walkdown, the inspectors performed a walkdown of portions of Component Cooling Water System Trains A and B, which included components inside containment and the mechanical auxiliary building. Component Cooling Water System Train C was not selected because the licensee had not performed their final walkdown. This walkdown was performed to verify the completeness and accuracy of the licensee's walkdown and identification of component problems. The licensee's, walkdown was conducted in accordance with system attributes as described in Station Procedure OTGP03-ZA-0006, Revision 1, " System Acceptance." Plant personnel and the procedural checklist were found to have a low threshold for .
deficiency identification. This was further indicated by the licensee's punchlist of housekeeping and minor repair items, and service requests written subsequent to the system walkdown.
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NRC Inspection Procedures 71707, " Operational Safety Verification"; and 71710,
" Engineered Safety Feature Walkdown," were utilized by the inspectors during the in plant walkdown. Overall, both trains were in excellent conditio Only four minor deficiencies were identified by the inspectors. The system
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-39-engineer accompanied the inspectors on portions of the walkdown and initiated the appropriate work documents for the identified problem areas. Based upon the review of the licensee's walkdown of the component cooling water system and the inspectors' independent review, Trains A and B were considered capable of supporting restar The inspectors also reviewed the licensee's- deferral justification forms for naintenance items that were determined not to require work during the outag The inspector determined that the deferral justifications were appropriat Field verification and a technical manual review of the components identified no immediate or long-term operational concern Following the licensee's walkdown, the inspectors also performed an independent walkdown of the main control room heating, ventilation, and air conditioning system. The inspector observed the equipment areas and the ,
specific components included within the scope of the team's walkdown. No discrepancies were identified that were not included in the licensee's walkdown packag ;
The licensee's inspection appeared to have been thorough, and the system was considered to be in good condition. The inspector observed accessible portions of the system ductwork, dampers, structural supports, and ventilation fans. All items appeared to be properly installed and in good condition. The portions of the system observed were considered ready to support plant restar Additionally, portions of systems were observed during routine resident plant tours. When discrepancies were noted, the final system readiness. package was reviewed to determined if the item had been identified by the licensee's walkdown. No inconsistencies were noted between system condition and the walkdown repor .3 Punchlist item Review During the licensee's system certification walkdowns, the walkdown teams identified numerous items that needed to be corrected. Not all of these items involved physical work, and a number of items involved very minor activitie Examples of such items included: housekeeping items; removal of heavy equipment; decontamination of plant components; addition of coatings or paint.;
and replacing fasteners on nonvital components. These items were added to a punchlist to track the completion of each item. Following a plant walkdown, the team would decide which items required the issuance of station service .
requests. All other walkdown deficiencies were added to the punchlis '
The inspectors expressed concern that the punchlist may include items which .
should be performed under a service request. Therefore, the punchlist could cause the tracking of the service request backlog to be unrealistic. The licensee stated that any punchlist items which required service requests would have the proper documents issued by;the responsible organization. The
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-40-inspectors verified that this was being done by a review of a number of closed punchlist item The inspector reviewed the punchlist to determine the extent of the work required. The inspector also reviewed Station' Procedure OPGP03-ZA-0090, " Work Process Program," Revision 7, and compared the requirements of the work process procedure to the items identified on the punchlist. Of the hundreds of punchlist items reviewed by the inspector, approximately 20 percent of the items appeared to potentially meet the examples of minor maintenance listed in
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Addendum 2 of the work process procedure based on the description of the item in the punchlis This observation was discussed with the manager in charge of maintaining the punchlist and obtaining corrective actions. The manager's position was that the punchlist categorization was a "first cut" by the initial team identifying the item. Once the item was assigned to a work organization for action, the work group receiving the responsibility for the item would review the item, determine what work was necessary, and either perform the activity or generate a service request if required. With the large number of items identified on the punchlist, a vulnerability existed that the threshold for performing maintenance under the punchlist, without the proper work control documentation, could be inadequat Licensee management should be aware of this possibility and ensure that appropriate work control processes were utilized in accordance with established site procedure Because a formal system did not exist for maintaining an ongoing punchlist, licensee management decided that the punchlist would be completed, in total, before plant restart. The inspector noted that this was conservative because the punchlist items did not specifically cause the systems to be inoperativ However, the licensee had committed in the Operational Readiness Plan to '
upgrade the material condition of the plant prior to restart. By the end of the inspection period, plant personnel had shown considerable progress toward closing the punchlis .4 Closure of the Restart Issue As documented in NRC Inspection Report 50-498/93-36; 50-499/93-36, the inspectors reviewed the scope and detail of the system. readiness review These appeared to be adequate to meet the licensee's commitments in the Operational Readiness Plan. The system engineers' reviews were determined to'
be comprehensive, and the management review and approval process was stated to have had a positive impact on system readines During this inspection period, reviews consisted of observation of the system walkdowns in progress and independent assessment of system readiness via walkdown of selected systems. Additionally, a review was performed of the system walkdown punchlist to ensure that the identified items were being corrected in an acceptable and timely manner. The inspectors noted that the identification of outage scope items was conservative. Continued resident
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I-41-inspection should ensure that the outage scope was completed or properly dispositione Based on these activities, Restart Issue 13, " Monitoring of the Licensee's ,
System Certification Program," identified in NRC Inspection Report 50-498/93-31; 50-499/93-31, was considered resolve .5 Statusing of Items Related to the Restart Issue (92701)
The followin'g items related to Restart Issue 13 were statused concerning the I~
manner in which the licensee had implemented the system certification progra One of these items was broad scoped and covered numerous licensee systems and [
programs. This item remained open pending further NRC inspection effort to '
completely resolve the item during future restart inspection . (Closed) IFI 498;499/93031-35: System Certification and Acceptance Process As documented in Section 8 of this report, the inspector reviewed the licensee's procedures governing system certification and acceptanc System readiness review packages were comprehensive and demonstrated that outstanding ,
items were appropriately evaluated and dispositioned. . Additionally, a system !
walkdown was performed and the systems were accepted by the shift supervisor and plant manager. Although the second process was still ongoing, the ;
procedures and implementation to date had shown that the process was sound and conservativ ;
8. (0 pen) IFI 498;499/93031-53: Continued Operation Assessed'at Different Milestones At the end of this inspection period, the systems required for the_ Mode 4 milestone had been walked down; and a final readiness review package had been developed. Work on open outage items was continuing and all indications pointed to the successful certification and acceptance of these systems. This process was supported by system engineering management and reviewed by the :
operational readiness review panel and the nuclear assurance organizatio l These packages when complete and accepted should provide an excellent tool to support management's assessment for the evaluation of restart milestone ' '
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The inspectors reviewed the licensee's actions for operational assessment related to the system certification progra Based on this review, :
IFI 498;499/93031-53 was closed with respect to Restart Issue 13. However, .
based on its generic nature, this item remained open pending further NRC .
restart issue inspection .6 Assessment of Management's Receptiveness to Identifying and Correcting Plant Problems (92720)
The inspettar determined that throughout the system certification program, management had been active in evaluating and correcting plant problems. A ;
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previously noted, management took corrective action in providing additional guidance to the walkdown teams when deficiencies were noted. Management was instrumental in developing and managing the punchlist items to insure timely correction of deficiencies identified and to ensure that the walkdown process resulted in improved material condition of plant system FOLLOWUP 0F CORRECTIVE ACTIONS FOR A VIOLATION AND AN OPEN ITEM (92701 and 92702)
9.1 IClosed) Open Item 498:499/91003-01: Weaknesses Identified during the Conduct of Operator Walk Throughs and Interviews The weaknesses associated with this open item related to scenario events that were overclassified or misclassified, and an observation of weak dose assessment. Since these items were identified in 1991, the performance of licensee shift crews and emergency responders has been inspected during walk throughs, as documented in NRC Inspection Reports 50-498/92-10; 50-499/92-10, 50-498/92-22; 50-499/92-22, and 50-498/93-25; 50-499/93-25 and during emergency exercises documented in NRC Inspection Reports 50-498/91-20; 50-499/91-20, 50-498/92-09; 50-499/92-09, and 50-498/93-17; 50-499/93-17. In each of these inspections, operating crews and emergency responders were evaluated in their responses to scenarios which provided challenges similar to those which resulted in the weaknesses associated with this open ite In several of these inspections, weaknesses were identified in the same categories as those associated with this open item. Any uncorrected or recurring weaknesses related to the categories associated with Open item 498;499/91003-01 were tracked as weaknesses identified during these subsequent inspections. Specifically, classification weaknesses were tracked by Exercise Weakness 498;499/93017-01 and Emergency Preparedness Weakness 498;499/93025-03. A dose assessment weakness was tracked by Emergency Preparedness Weakness 498;499/93025-04. Based on the results of the emergency preparedness inspections conducted since 1991, these weaknesses were resolve .2 (Closed) Violation 498:499/91014-01: Failure to Augment the On-shift Emergency Response Organization within 45 to 60 Minutes as Required by the Emergency Plan By letter dated May 20, 1993, the NRC approved a revision to the licensee's emergency plan that increased by 15 minutes the amount of time allowed for specified emergency response positions to report to the site to augment the onshift emergency response organization. During the NRC Inspection conducted August 2 through 6, 1993, as documented in NRC Inspection Report 50-498/93-25; 50-499/93-25, Section 7.1, the inspectors reviewed the results of recent staff augmentation callout drills focussing on those conducted since the May 20 plan change. Only three actual drills that required responders to return to the site had been performed since December 1992. However, these drills were not evaluated for response tim ..
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e-43-Six augmentation drills had been evaluated for response timeliness since the emergency plan chang The drills _ included a notification of the entire on-
~ duty emergency response organization by either pager activation or manual telephone callout. Responders called in with their estimated times to respond. In these drills, there were isolated cases where designated responders would have been unable to respond within the timeliness' criteri For these individuals, however, the estimated response times would have exceeded the criteria by only minutes. Except for these isolated cases, the required initial staff augmentation response. times were met. Based on th results of these drills, the inspector concluded that the licensee's initial staff augmentation time criteria could be met.
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.e ATTACHMENT 1 PERSON CONTACTED 1.1 Licensee Personnel M. Berry, Design Support Manager H. Butterworth, Manager, Plant Operations (Unit 1)
T. Cloninger, Vice President, Nuclear Engineering F. Comeaux, Consulting Engineer, ISEG K. Coates, Maintenance' Manager (Unit 2)
J. Conly, Licensing Engineer W. Cottle, Group Vice President, Nuclear P. Dahl, Licensing Consultant D. Daniels, Administrator, Corrective Action R. Ferguson, Licensing Consultant D. Fisher, Supervising Engineering Specialist J. Groth, Vice President, Nuclear Generation R. Helton, Assistant Maintenance Manager (Acting) (Unit 1)
J. Johnson, Supervisor Quality Assurance T. Jordan, Manager, Systems Engineering Department W. Jump, Director Regulatory Activities Support J. McIntyre, Manager, Engineering Support Division B. MacKenzie, Senior Counsulting Engineer M. Pacy, Manager, Programs Division P. Parrish, Senior Specialist S. Parthassarathy, Supervisor, Design Engineering Department R. Rehkugler, Manager, Nuclear Quality Control and Material Testing D. Rencurrel, Assistant Maintenance Manager (Unit.2)
J. Sheppard, Nuclear Licensing M. Selman, Consultant M. Smith, Senior Consultant J. Soward, Supervisor, Administrative Nuclear Assurance <
C. Stephenson, Licensing Consultant D. Stonestreet, Outage Manager K. Taplett, Manager, Nuclear Safety Quality Concerns Program .
S. Thomas, Manager, Design Engineering Department D. Towler, Supervisor, Quality Assurance Operations T. Underwood, Manager, Maintenance Support L. Walker, Licensing Consultant i J. Wittman, Supervisor, Work Control In addition to the personnel listed above, the inspectors contacted other personnel during this inspection perio .2 NRC Personnel T. McKernon, Reactor Inspector T. Westerman, Section Chief, Reactor Safety Engineering Section W. Johnson, Section Chief, Reactor Project Section A I
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l.3 Other Attendees D. Shultz, NRC Consultant 2 EXIT MEETING An exit meeting was conducted on December 21, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The inspectors also-passed on NRC concerns with leak sealant usage in the plant and with the large number of punchlist items identified during system certification walkdown The licensee acknowledged the information presented at the exit meeting with no comments or question The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector LJ