IR 05000498/1994006
| ML20059K566 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/26/1994 |
| From: | Vincent Gaddy, Johnson W, Mckernon T, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059K560 | List: |
| References | |
| 50-498-94-06, 50-498-94-6, 50-499-94-06, 50-499-94-6, NUDOCS 9402020163 | |
| Download: ML20059K566 (18) | |
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. APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report: 50-498/94-06 50-499/94-06 Licenses: NPF-76 NPF-80 Licensee: Houston Lighting & Power Company P.O. Box 1700 Houston, Texas Facility Name: South Texas Project Electric Generating Station (STPEGS), Units 1 and 2 Inspection At: Matagorda County, Texas Inspection Conducted: January 10-14, 1994 Inspectors: T. O. McKernon, Reactor Inspector, Project Section A Division of Reactor Projects R. B. Vickrey, Reactor Inspector, Project Section A Division of Reactor Projects V. G. Gaddy, Reactor Inspector, Maintenance Section Division of Reactor Safety Approved: ///DC)nson, N , Project Section A '/,2 6/ 9 9 W . D .~
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Date Divisi of Reactor Projects Inspection Summary Areas Inspected (Units 1 and 2): Routine, announced inspection of restart related items from previous inspection finding ' Results (Units 1 and 2):
* A number of restart-related items were closed or reviewed and left ope * Sufficient improvement has been made with regard to Restart' Issue 14, " Adequacy of the Licensee's Resolution of the Reliability and Operability of the Feedwater isolation Bypass Valves," to recommend closure pending successful operational testin PDR ADOCK 05000498- -
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l-2-Summary of Inspection Findings:
* Inspection Followup Items (IFIs) 498;499/9208-01,-9324-01,-9335-01,
-9331-05, -9331-25, -9331-54, -9331-55, -9331-57, -9331-61, and -9116-02 were close * Violation 498;499/9217-02 was close * Violation 498;499/9303-01 was reviewed and left ope * Licensee Event Report (LER) 498/93-020 was close * LER 499/93-008 was reviewed and left ope Attachments:
* Attachment - Persons Contacted and Exit Meeting
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DETAILS 1 BACKGROUND Both units at STPEGS were shut down in early February 1993 and remain shutdown as a result of numerous broad scoped problems identified by the NRC and the licensee.
' NRC Inspection Report 50-498/93-31; 50-499/93-31, issued on October 15, 1993, 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 14,
" Adequacy of the Licensee's Resolution of the Reliability and Operability of the Feedwater Isolation Bypass Valves," and to establish a basis for concluding that this Restart Issue has been adequately resolved by the licensee. In addition, this inspection reviewed other previously identified inspection finding REVIEW OF ITEMS RELATED TO RESTART ISSUES (92701)
The following items related to Restart Issues were reviewed concerning the manner in which the licensee had resolved the issues. They will remain open pending further NRC inspection effort to completely resolve the items during future inspection .1 (0 pen) Violation 498:499/9303-01: Failure to follow procedures for performina self-verification This violation involved eight instances in which licensee personnel did not verify the correct device, did not ensure they were on the correct unit, did not ensure they were on the correct train, or otherwise complete the self-verification program required by Procedure OPGP03-ZA-0010, " Plant Procedure Adherence and Implementation and Independent Veyi.fication."
The licensee initiated corrective actions to. address personal accountability issues-and programmatic support. Personal accountability issues, such as self-verification and attention to detail, had not' been adequately ; implemented. Programmatic support of workers had not provided fully'effectiv'e barriers to personal performance errors; specifically, clarity of written guidance, adequacy of oral briefings and instructions, adequacy of equipment' design and labeling, and the repeated assignment of the same individuals for critical task The licensee's personal accountability corrective actions were: ) l
= The Plant Manager met with crew leaders and planning supervisors to j discuss expectations and receive recommendations on corrective action !
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The maintenance manager suspended field activities to discuss wrong unit / train / component events with craft personnel. Crews met to formulate suggestions for improvement. A plant bulletin on " Attentio to Detail" was issued. The Group Vice President, Nuclear briefed the maintenance, operations, and engineering personnel on lessons learne * Human Performance Review Boards were established to review selected human performance events and determine the causal factors of these event * Supervisors and managers were stressing self-verification and attention to detail in routine meetings. In addition, actions were being taken to identify and remove barriers to supervisor time in the work plac Maintenance assigned two supervisors per crew concept effective January 3, 199 * Personnel on dedicated work teams were being rotated to minimize desensitization from performing the same task repeatedly. The training plan supported this rotation and managers were sensitive to the concep * The self-verification program was enhanced with a STAR (Stop, Think, Act, and Review) process on July 31, 199 * The Plant Manager instituted a Plant Manager's Forum with line personnel to discuss issues such as human performance expectations and employee identified problem areas on May 10, 199 . Maintenance managers were conducting discussions with first-line 1 supervisors to explain management's expectations regarding personnel accountability. These discussions were planned to be completed by mid-Februar !
* The use of Human Performance Review Boards and-implementation of the- l Constructive Discipline Program were determined to be the proper ! . mechanisms to reinforce the importance of personnel awareness, attention to detail, and self-checking following human performance related event The licensee's programmatic support corrective actions were: * Unit identification placards were installed at the main access points. ' i The service request checklist was modified to include barriers to reduce - '
wrong unit / train / component errors. Existing work packages were stamped with a unit designator. New work packages' have the unit number included i in key locations. Work packages have been modified to remove extraneous ; information, include discrete steps prior to starting work, and streamline the precaution and prerequisite section . A video tape on self-verification has been presented in crew meetings. A self-verification trainer was being utilized to . l
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-5-practice the , kills of. self-verification and verbal communication under actual task performance condition * An augmented work control program was implemented on critical tasks through Maintenance Department Standing Order MG-17 on March 7, 199 . Self-verification techniques were being reinforced through the use of signs, posters, hard hat stickers, et Supervisors were stressing self-verification principles and the need to be mentally prepared in prejob briefing * A Surveillance Enhancement Program was initiated. An enhanced sitewide surveillance procedure writer's guide that incorporated good human factors practices and site procedure performance policies became effective on October 20, 1993, and 51 high priority surveillance procedures were completed and issued by December 17, 1993. The remaining procedures are scheduled for completion by December 199 * The plant labeling program is being upgraded. The labeling project scope had been developed and a contract awarded. The labeling upgrade project was scheduled to be substantially complete by December 199 * A new shift rotation schedule has been implemented in an effort to improve overall morale and minimize distraction * The results of an Organizational Interface Assessment have been evaluated for issues that affect human performance. The licensee has established a senior management steering committee to address the . l recommendations in the assessment and develop and oversee implementation of a plan of action for.each recommendation. This activity was incorporated into the STPEGS Business Plan with full implementation scheduled by December 31, 199 * A new goal and action plan which deals exclusively with human , ,.
performance has been incorporated into the STPEGS Business Plan with full implementation scheduled by December 31, 199 j While the licensee has continued to experience additional examples of ' personnel error, they believed that' these corrective actions, once fully implemented, will be effective in precluding the recurrence of similar j problem .j in an effort to continue to seek the most effective methods to implement its- - goals of human performance improvement, the licensee had taken additional efforts including:
* The addition of five personnel experienced in human performance issue .i
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* The identification of a Human Performance Coordinator with a specific goal of helping line departments improve human performance on August 9, 199 * Initiatives, such as setting aside one day a week where station meetings are minimized, aimed at getting management and supervision into-the field and in contact with station personnel. The licensee was continuing its policy of minimizing station meetings one day per wee Other initiatives included the establishment of the Operations Work Control Group and instituting the two supervisors per crew concept in maintenanc Additionally, in response to a personnel error event that occurred on April 20, 1993, corrective actions included:
* Plant management instituted a Human Performance Improvement Day on April 23, 1993, where virtually all field activities were suspended to allow station personnel dedicated time to identify methods to improve human performanc Plant-wide meetings were conducted to discuss human performance and solicit suggestions. An action plan was developed in May that incorporated these suggestions. The action plan objectives were to: (1) identify and implement near-term actions to improve human performance during the Unit 1 startup; (2) ensure near-term actions are compatible with long-term activities to improve human performance; and .
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(3) involve affected plant personnel to obtain their input and program suppor * Plant management directed station personnel to limit work hours to no more than 60 hours per week and to allow at least 2 consecutive days off after each work period. Exceptions to this directive, issued May 28, 1993, required management approva While the inspectors recognize that the licensee's corrective actions that have been fully implemented may have had an effect in reducing the recurrence of similar problems, several corrective actions still have not been fully implemented. Recently, the licensee has continued to experience recurrence of similar problems. In view of continued problems in this area, this violation will remain open pending further implementation of the licensee's currently planned corrective action ,
2.2 -J0 pen) LER 93-008: Technical Specification Violation Due to a Failure to Maintain Environmental Qualification of a Residual Heat Removal Motor-
-Operated Valve (MOV)
On May 5, 1993, with Unit 2 defueled, the licensee discovered that an'MOV had not been environmentally qualified since Hovember 29, 1990, because replacement of a "T" drain had never been completed. The motor of Valve RH-0060B was being replaced because the associated supply breaker tripped on overcurrent. Once the motor was replaced, workers attempted to replace the
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"T" drain, but the correct size "T" drain was not readily availabl Prior to beginning the work activity, the shift supervisor reviewed a service request which authorized installation of the "T" drain. The shift supervisor failed to realize that the service request affected the environmental qualification of the M0 On May 5,1993, the NRC Diagnostic Evaluation Team alerted the licensee of the-deficiency regarding the "T" drain. The licensee determined that the absence of the "T" drain rendered the valve inoperable in a harsh environment following a postulated design basis accident. This resulted in a violation of Technical Specification 3.5.6. The licensee attributed the failure to a lack of knowledge regarding the requirements to maintain the environmental qualifications of MOV .
During a review of the LER, the inspector noted that segments of the licensee's corrective action related to this LER had been previously addressed in NRC Inspection Reports 50-498/93-35; 50-499/93-35 and 50-498/93-19; 50-499/93-19. However, since the issuance of these reports, the licensee has issued Revision 2 of this LER which revised portions of the corrective actions that had been previously evaluated by the NR Thus, portions of the-licensee's corrective ' actions will be revisited due to this additional informatio ~ The licensee had previously reported in Revision 1 of LER 93-08 that a 100 percent walkdown of harsh environmental MOVs for Units 1 and 2 had been performed in May 1993 to determine if potential operability issues existed due to "T" drain discrepancies. The licensee reported that a total of four MOVs with discrepant "T" drains had been identified during the walkdown. The discrepant. valves were corrected. The licensee subsequently discovered that not all harsh environment MOVs had been included in the May 1993 walkdow Four valves had been inadvertently omitted during the walkdown. These valves were inspected in November 1993, and no anomalies were discovere In Revision 1 of the LER, the licensee committed to provide equipment qualification training to system engineers, senior reactor operators, maintenance planners, electrical, instrument and control, and mechanical maintenance personnel. -During a review of the class attendance rosters, the inspectors discovered that not all designated personnel had received the required trainin The licensee initiated Station Problem Report (SPR) 940083, dated January 13, 1994, to document this deficiency. Th'e - SPR was assigned Category 3, which requires that a root cause be performed to : determine why the training was not. complete The licensee als'o committed to include equipment qualification and configuration management as topics for continuing education for system engineers and quality control inspectors. This had not been completed and was scheduled for completion by August 199 The inspectors verified that all remaining corrective actions committed to had been implemente , _ -- _, _ . _ . _ . -
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-8-This item will remain open pending the completion of equipment qualification training for all designated personnel and also the establishment of the continuing education training for system engineers and quality control inspector CLOSED ITEMS RELATED TO RESTART ISSUES (92701)
The inspectors determined that the licensee's actions to address the following . concerns were adequat .1 (Closed) Inspection Followup Item 498:499/9331-54: In order to assure a consistent and integrated approach to the internal assessment'orocess, a Line Management Assessment Plan will be prepared by line management and approved by the Group Vice President. Nuclear prior to core reloa The inspectors reviewed Revision 1 of the licensee's Line Management Assessment Plan, dated October 28, 1993. The plan was signed by the Group ; Vice President, Nuclear. The purpose of the plan was to provide guidance for i assessing-operational readiness by line management. The plan focused on i' hardware issues, programmatic issues, human performance, and organizational performance issues to assess the readiness of line organizations to ascend to the next operational milestone. Attached as an appendix to the plan was an organizational self-assessment checklist which provided examples of areas in which line organizations should prepare assessments. In addition to the areas ,
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addressed above, the checklist also requested that assessments be made of the organizational work backlog, organizational commitments, and ' staffin The assessments are reviewed by the Plant Operations Review Committee (PORC) for organizations reporting to the Plant Manger and by the Operational Readiness Review Panel (0RRP) for organizations that report outside the Plant Manager. However, the licensee's standard practice is for the ORRP to review all assessments, even those that are reviewed by the PORC. The ORRP consisted of representatives of the licensee's senior management -staf Prior to presentation of the line organization's Mode 4 self-assessment to the - ORRP, the licensee issued a memo to all line organizations requesting that , they not only be prepared to make a presentation of the methods and conclusions of- their self-assessment but to address key performance l indicators, determination of areas at risk, contractor utilization necessary ! for Mode 4 entry, and justification for deferrals or noncompletion of a work activit 'i Additionally, the PORC reviews the plant systems necessary to support the next ! milestone. This information is provided from the System Certification Process and normal plant operation readiness procedures. Based on the results of the self-assessments, the system certifications, and the operational readiness i procedures, the Plant Manger makes a readiness recommendation to the ORR In addition to the above reviews, the ORRP reviews all restart issues to ensure they are given the necessary attention to facilitate their resolutio ,
_g_ included in these reviews are the items detailed in the NRC's Confirmatory Action Letter and Supplements. The ORRP also reviews plant readiness, including SPRs, backlogs, performance trends, and performance indicator From these reviews, the ORRP assesses management effectivenes When the Plant Manager and the ORRP are satisfied that the plant is ready to proceed to the next milestone, a joint recommendation to proceed is made to the Group Vice President, Nuclea The line organizations performing the assessments include Nuclear Engineering (Plant and Design Engineering), Nuclear Generation (Maintenance, Operations, Technical Services, Outage, and Work Control), Corrective Action, Nuclear Licensing, Nuclear Training, Nuclear Assurance, and Planning & Assessmen The above line organizations conduct self-assessments at the following intervals:
* Prior to core reload * Prior to Mode 4 * Prior to Mode 2 * Prior to proceeding above 50 percent reactor power * Prior to proceeding above 90 percent reactor power -i * After completion of 10 days of 100 percent reactor power The inspectors attended the Mode 4 assessment presented by the Outage Management Department to the ORRP. The areas assessed were ,
commitments / corrective actions, work product anc' processes, staffing, human performance, and coordination with the work control center. The assessment identified areas with satisfactory performance and areas that required improvements. However, none of the items identified effected a Mode 4 entr In fact, corrective actions for these deficiencies had either already been completed or were in progres ' The Outage Manager stated that a low threshold had been set for equipment i deficiencies. As a result, the licensee was confident that all equipment ! problems were being identified and remedie j Currently, Mode 3 entry is scheduled for 2 days after Mode 4 entry. The -l Outage Manager stated that this was a very aggressive schedule but felt that l it could be achieved. The licensee indicated that the major contractors are
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-10-The Outage Management assessment did not identify any issues that were :
characterized as Mode 4 restraint .2 (Closed) Inspection Followup Item 498: 499/9331-55: Independent Assessment Plan During this inspection, the inspectors reviewed findings of the periodic (biweekly) Quality Assurance reviews which provided input to the running report card. The report card tracked weekly and more recently (biweekly) - progress in key topic areas (e.g., Plant Operations, Corrective Action, anc others). As previously reported in NRC Inspection Report 50-498/93-54; 50-499/93-54, the licensee continued to consider postmaintenance testing, corrective actions, and configuration management as areas warranting continuet emphasis. For the independent assessment' results review ending December 30, 1993, the licensee showed rating upgrades for corrective action and configuration management areas. Rationale for the upgrades included better ' classification of SPRs by the problem review group and the multidiscipline group reviews. Configuration management had shown improvement as a result of the licensee recognizing an adverse trend, a review team task force was established to address the concern, and the two craft supervisor programs had been implemented. Further, although the licensee had'taken programmatic corrective actions to resolve weaknesses in the postmaintenance testing area, no subsequent measures of corrective action measurement had been made'to assess the effectiveness of the changes. In addition, at the time of this inspection, the Quality Assurance group was performing surveillances of the ' corrective action program. These surveillances were intended to review closed Category 1-4 SPRs for adequacy of operability reviews performed since January 1993. Another part of the surveillance reviewed closed SPRs for adequacy of root cause analysis, adequacy of remedial and corrective actions, , appropriateness of the assigned category, and the presence.of'any unaddressed issue which could impact plant restart. The preliminary results of the latter surveillance indicated that sometimes root cause analyses were not performed or were inadequately performed, remedial and/or corrective actions were less I than adequate, and the generic implications were not well addresse l l
While the surveillance results indicate that weaknesses within the corrective action area still exist, the independent assessment process has been an effective tool in identifying these weaknesses and providing feedback to i senior management and the responsible organization l In addition to the above, the Nuclear Safety Review Board (NSRB) reviewed the Restart Issues identified in the Operational Readiness Plan and supplemented them with six additional issues. The NSRB recommended that contingency plans for anticipated occurrences during startup be developed; that root causes of a recent boron dilution event be addressed; performance of an evaluation of the impact on operations and maintenance before moving instrument and control l surveillances to the day shift; ensuring that operations feedback forms receive a thorough review; management review lessons learned from Refueling Outage IRE 04 and startup; and engineering provide oparations with updated information on expected core response during startup and power ascension. The i l
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s NSRB hao been asked to provide an independent input to the Group Vice President, Nuclear's decision making proces . (Closed) IFI 498:499/9331-05: " Management has sent confusing and conflicting quidance to the control room staff through numerous memoranda without soliciting input from the first line supervisors." , This item involved communications between management and the control room ! staff which at times contradicted prior communications and the lack of effective feedback from the operating crews to management on decisions-and policy developmen As corrective actions for this item, the licensee has implemented changes to the operations policy and practices manual administrative procedure (OPGP03-Z0-0040) to implement better controls on the use of memoranda for establishing operating policy. These included: establishing guidance for handling information that could potentially be Technical Specification Interpretations; guidance on the formal routing of memoranda involving potentially Technical Specification Interpretations; and required review of the memorandum and night orders section by the unit operations manager to select those items for incorporation into the policies and practices manua Periodic reviews of this manual will be accomplished every 6 month ,
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Further, the plant managers, operations managers, and shift supervisors meet biweekly to discuss issues, standards, and plans. This forum allows for immediate feedback to management as well as management representation during a shift briefing each crew cycle. Additionally, operations support managers and both plant managers and operations managers meet several times weekly to ensure that policies are set consistently for both units. Also,' the Vice President, Nuclear Generation has met with employees in small groups to discuss problems and ideas for enhancement. Long-term corrective actions have been incorporated into the STPEGS Business Plan. Business Plan Initiatives A1, B1, B2, and B3 will: standardize a process for communicating goals, standards, responsibilities, expectations, and measuring success at all . . levels; foster a culture and develop processes that promote station standards ! for communication, teamwork, recognition and pefsonnel development; improve personnel goal development and decision making; and maximizing communication tools with effective feedback, respectivel ; (Closed) Inspection Followup Item (498:499/9208-01): Reactor coolant-system overcooling The cooldown event occurred because of excessive secondary plant heat loads and a lack of sufficient anticipation-by control room operators of the effect that secondary steam loads would have on reactor coolant temperatures during low power operations. The licensee's actions to resolve excessive cooldow , during Mode 3 and low power operations was tracked by this inspection followup .! ite I i i
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-12-The licensee's corrective actions included: * Repair of the steam dump valves and the installation of orifices in the main steam system drains; * The removal of the procedural hold at the previously required lx10E-8 amp low power plateau data collection point, prior to opening the main generator output breaker, to preclude the specific shutdown delay associated with this event and associated operator burdens; and * The development of the Plant Operations Department Reactivity Management Policy and training of operations personnel, including shift technical :
advisors on the specifics of the even The licensee had completed the repair of the steam dump valves. The installation of orifices in the main steam system drains was reviewed in NRC Inspection Report 50-498/93-54; 50-499/93-54 discussed belo Procedure OPGP03-ZO-0042, Revision 0, " Reactivity Management Program," was approved on November 8, 1993, included in the shift technical advisor and licensed operator requalification training cycle which began on November 9, 1993, and became effective on December 10, 1993. Procedure OPOP03-ZG-0006, Revision 0, " Plant Shutdown from 100% to Hot Standby," effective September 14, 1992, revised 1(2)P0P03-ZG-0006 to minimize secondary heat loads prior to l going below 5 percent power, caution operators of possible cooldown transients, and eliminate the 10E-8 amp data collection poin This item was closed based on the licensee's corrective action described above and the licensee's corrective action described in NRC Inspection Report 50-498/93-54; 50-499/93-54 for Inspection Followup Item 498;499/9331-0 .5 (Closed) LER 498/93-020: Entry Into Technical Specification 3.0.3 Due to the Feedwater Isolation Bypass Valves Being Determined to be Inoperable This LER was closed based on the licensee's corrective actions concerning IFl 498;499/9324-01, ilescribed in Section 3.6 of this repor .6 (Closed) Inspection Followup Item (498:499/9324-01): Inadequate i feedwater Isolation Bypass Valve Spring Design This item was reviewed in NRC Inspection Report 50-498/93-35; 50-499/93-3 l
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For the main steam isolation bypass valves, the actuator springs were to be replaced. For the feedwater isolation bypass valves, the valve stroke was to j be decreased in order to preload the existing closing spring and increase the actuator thrust. The existing valve adjusting screw was to be replaced and
the valve plug modified to accommodate the decreased stroke requirement. In )
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addition, the unbalanced valve trim was to be replaced with a pressure-balanced trim, thereby reducing the thrust required to close the vafve. For
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-13-the feedwater preheater isolation bypass valves, the valve-stroke was to be decreased and the existing valve adjusting screw and valve plug replace The inspectors reviewed the licensee's Unit 1 completed work packages for the above mentioned planned actions. With the exception of the performance of operational leak checks with the system'at normal operating temperature and pressure, all work and postmaintenance testing items were complete. The licensee had completed the corresponding Unit 2 design work and issued service requests which were scheduled for completion prior to startu Although the licensee had not completed the operational leak checks for Unit 1 or the planned work for Unit 2, based upon the licensee's progress and completed actions to date, this item was considered closed and sufficient actions had been completed to recommend clnsure of Restart Issue 1 .7 (Closed) IFI 9331-57: "Six Shift Rotation" This item involved the implementation of the six-shift rotation of operating Crew The inspectors verified that the six-crew rotation had been implemented as of January 1, 1994. Further, the inspectors observed a shift turnover briefing to verify discussions pertinent to work activities and control room responsibilities were held. A review of the January 1994 operation support schedule for Unit 1 indicated the six-crew rotation and accounted for a licensed operator requalification training week, regular days off, vacation, and holidays as well as the 8-hour and 12-hour operations work shifts. This item was initially reviewed in NRC Inspection Report 50-498/93-41; 50-499/93-4 '
3.8 (Closed) IFI 9331-25: Threshold of SPRs. Depth of Root Cause Analyses not well defined or communicated to the staff This item is closed based upon the licensee's corrective actions in response to Violation 498;499/9217-02, discussed in Secti.on 3.10 of this report .9 (Closed) IFI 9331-61: Two Supervisors for each Maintenance Crew During this inspection, the inspectors verified that the licensee had ' _ implemented a schedule using two supervisors for each maintenance crew effective January 3, 199 .10 (Closed) Violation 498/9217-02:499/9217-02: Failure to report a condition adverse to auality to the shift supervisor After declaring the reactor trip system for both units inoperable, the licensee entered Technical Specification 3.0.3. The licensee did not inform < the shift supervisor of the Technical Specification 3.0.3 entry until approximately 21/2 hours later. Additionally, the condition was not promptly documented in an SPR as required by the licensee's procedur The licensee
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failure to notify the control room of an operability determination, (2) confusion over the implementation and interpretation of Technical Specifications 3.0.3 and 4.0.3, and (4) confusion over processes involved in cbtaining a Waiver of Complianc In response to the violation, the licensee initiated the following corrective ' actions:
* Plant Bulletin 196, dated June 24, 1992, was issued to reiterate the - ,
contents of Interdepartmental Procedure IP-1.450, " Station Problem Reporting," dated December 27, 1991. The Bulletin stated in part that, if a condi' inn appears to require immediate response, the originator shall fir
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oport the condition to the shift supervisor, then initiate an SP The Bulletin further stated that all SPRs should be taken to the control room for evaluatio * Nuclear Group Policy-130, " Reporting Safety-Related Concerns or Problems," dated September 22, 1992, was revised to emphasize that all ' questions affecting the operability of systems, structures, and components should be fromptly notified to the shift supervisor. The policy was also revised to state that the shift supervisor has the ultimate responsibility for determining operability of systems, structures, and component i
* Plant Operation Policy 0-0018 was written to clarify the plant's policy '
with regard to Technical Specification 3.0.3 entries and Technical Specification 3.0.3 shutdown '
* The licensee developed Technical Specification Interpretations to ,
clarify Technical Specification 3.0.3 and provide more detail on the , applicability of Technical Specification 4. * Interdepartmental Procedure IP-1.96Q, " Guidance for Temporary Waivers of ; Compliance," dated September 25, 1992, was issued to formalize the process for obtaining waiver .
, * The SPR initiation threshold was lowered to improve the timeliness of .
problem identification to the control room. The threshold for SPR , generation was lowered when the licensee issued Procedure OPGP03- l ZX-0002, " Corrective Action Program," dated September 9, 1992. This . procedure superseded Procedure IP-1.45Q, " Station Problem Reporting," dated December 27, 1991. This new procedure significantly expanded the scope of events that required generation of an SPR. The new procedure also made the Corrective Action Group responsible for screening SPRs for , reportability and operability concern During the period of 1987 to 1991, an average of 628 SPRs were initiated
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each year by the licensee. In 1992, a total of 1672 SPRs were i
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Corrective Action Program. procedure in September 199 In 1993, the new : procedure generated approximated 3600 SPR Based on these actions, the inspectors concluded that the licensee has taken the appropriate action to address the reasons for the violatio .11 (Closed) Inspection Followup Item (499/9335-01): This item involves the reclassification of a safety-related toraue arm key for a centrifugal charginq pump discharge isolation valve to nonsafety relate The reclassification was based on an architect-engineer memorandum dated September 10, 3986, which classified positioners as "non-safety." Since the positioners had been reclassified, the licensee had not established actions to ensure their ability to function as require This item remained open pending the satisfactory completion of a plant impact assessment on.the torque arm key for the centrifugal charging pump isolation valve since it hed alto been reclassified as nonsafety relate l
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The licensee identified in SPR 931818, dated May 21, 199.3, that the positioner ' performed a safety-related function. The license then initiated an evaluation , to identif,r if there were any generic qualification concerns with safety classification downgrades. The evaluation identified 21 parts that_ required' . reclassification to a safety-related status. The licensee completed impact _ assessments to determine if the incorrect classifications impacted operabilit ' Twenty of the 21 parts were evaluated in NRC Report 50-498/93-35; 50-499/93-3 The eemaining part involved a torque arm key for the ,
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centrifugal charging pump discharge isolation valve. The inspector assessed the actions outlined in the plant impact assessment to provide assurance that '
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the torque arm key would still perform its intended safety functio These actions included performing a stress analysis to establish the actual design margins for compressive stress in the key contact area with respect to the maximum allowable values. Actual values were within the allowable value The licensee also identified the class bin which procured the torque arm key Of the keys procured, only one had been installed. In reviewing results from j' the Commercial Grade Dedication Package for the in stock keys, the licensee ' determined that all but the key installed had been tested and inspected as required. They had also passed all acceptance criteri Based on a review of the actions taken by the licensee, the inspector :
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concluded that the licensee had taken the appropriate actions to ensure that ' the torque arm key would perform its intenued safety functio .12 1 Closed) IFI 498:499/9116-02: Operations Overtime During 1993 the operations department overtime rate was 24.9 percent for Unit I and 23.9 percent for Unit 2. The trend since fully implementing the ,
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sixth crew rotation has been to reduce overtime worked to approximately 19.6 percent. Further, reductions in overtime are anticipated as the unit becomes operationa LICENSEE'S EFFECTIVENESS IN IDENTIFYING, PURSUING, AND CORRECTING PLANT PROBLEMS (92720) .
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At the time of this inspection, the licensee had made significant progress in resolving plant problems, particularly hardware and equipment problem Additionally, progress has been made in resolving programmatic problems (e.g., implementation of the postmaintenance testing program) and in identifying problems and adverse trends particularly by the nuclear assurance grou However, weaknesses in the licensee's corrective action program and : configuration management areas still persist. The principal concerns are -{ related to work control processes, the operations staff real-time knowledge of *
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plant and component conditions, and ensuring work evolutions in the plant are performed in a safe environment. Recent examples of the above concerns are
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discussed in NRC Inspection Report 50-498/93-54; 50-499/93-5 ,
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. F ATTACHMENT
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1 PERSONS CONTACTED
, Licensee Personnel D. Bize, Licensitig Engineer .
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J. Blevins, Supervisor, Records Management and Storage J. Brick, Security Coordinator T. Cloninger, Vice President-Nuclear Engineering R. Cogdell, Security Training Supervisor J. Conly, Licensing Engineer W. Cottle, Group Vice President Nuclear J. Drymiller, Security Supervisor Administration
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F. Durham, Security Operations ' J. Groth, Vice President-Nuclear Generation M. ' Hall, Senior Security Coordinator M. Hardt, Director, Nuclear Division, City Public Service Board, San Antonio i T. Jordan, Manager,~ Systems Engineering M. Lance, Administrative Clerk J. Mason, Senior Security Coordinator !
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J. Northrop, System Engineer
.P. Parrish, Senior Specialist, Licensing E. Pomeroy, Security Coordinator A. Rodriguez, Senior Security Coordinator ;
S. Rosales, Engineering Associate, Licensing D. Sanchez, Manager, Nuclear Training Department D. Sheesley, Security Supervisor Systems . F. Timmons, Director Security D. Towler, Quality Assurance Operations Supervisor i G. Walker, Manager, Public Information H. Whitz, Contract Security Manager M. Woodard-Hall, Security Supervisor Support 1 In addition to the personnel listed above, the inspectors contacted other , personnel during this inspection perio I 1.2 NRC Personnel V. Gaddy, Reactor Inspector D. Garcia, Resident Inspector ,
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J. Keeton, Resident Inspector D. Loveless, Senior Resident Inspcetor T. McKernon, Reactor Inspector i D. Schuster, Senior Physical Security Inspector R. Vickrey, Reactor Inspector j
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The above listed licensee and NRC personnel attended the exit meetin EXIT MEETING An exit meeting was conducted on January 14, 1994. During this meeting, the inspectors reviewed the scope and findings of this report. The licensee did
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not take exception to any of the inspection findings and did not identify as proprietary any information provided to, or reviewed by, the inspector . k i l
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