IR 05000498/1996022
| ML20137G082 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/26/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137G061 | List: |
| References | |
| 50-498-96-22, 50-499-96-22, NUDOCS 9704010307 | |
| Download: ML20137G082 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
REGION IV !
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Docket Nos: 50-498,50-499 License Nos: NPF-76, NPF-80 !
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Report No: 50-498/96-22, 50-499/96 22 i
Licensee: Houston Lighting & Power (HL&P) i Facility: South Texas Project Electric Generating Station, Units 1 and 2
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Location: 8 Miles West of Wadsworth on FM 521 l l
Wadsworth, Texas 77483 i Dates: July 25,1996 through March 8,1997
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inspectors: D. P. Loveless, Senior Resident inspector '
J. M. Keeton, Resident inspector ;
. W. C. Sifre, Resident inspector l Approved by: J. l. Tapia, Chief, Project Branch A l Division of Reactor Projects
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i 9704010307 970326 I PDR ADOCK 05000498 -
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EXECUTIVE SUMMARY !
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i South Texas Project, Units 1 & 2 NRC Inspection Report 50-498/96-22,50-499/95-22 This special inspection included aspects of licensee operations, engineering, and maintenance. The report included multiple inspection activities performed by the resident inspectors occurring over a 7-month period. During the inspection, the circumstances surrounding a July 11,1996, failure of a plant tornado damper was reviewed. In addition, allissues identified as requiring review in the operational readiness assessment team
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inspection report were evaluated.
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Operations :
i e All open Operational Readiness Assessment Team items requiring corrective actions l
prior to restart had been properly reviewed and resolved at that time (Section O2.1). !
- Starting two reactor coolant pumps in January 1994 without properly restoring the ,
operability of reactor coolant system flow indication was a violation of procedure '
This event-revealed and licensee-corrected violation is being treated as a noncited !
violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section M8.1). ,
Maintenance
- All hardware-related restart issues were reviewed to ensure that restart-related >
commitments were still being implemented (Section M2.1). !
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- Previous preventive maintenance activities had been inadequate to identify the
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improper installation of the tendon gallory exhaust tornado damper. However,
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corrective actions taken following the identification of the construction deficiencies j were thorough and involved generic reviews of other hardware-related restart issues
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(Section M4.1).
l l * It was determined that erroneous information was reported in Licensee Event )
Report (LER) 50-498/94-003. The report state.d that the tendon gallery exhaust tornado damper was in a configuration that prevented full closure. This licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section M4.1).
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. . Table of Contents C '" \l LS . . . . . . . . . . . . . . . . . . . . . . ..............................1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1 O 2.1 Review of Operational Readiness Assessment Team (ORAT) Issues . . . . 1 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 08.1 ORAT Deficiency 1: Weaknesses in Configuration Management ...... 2 08.2 ORAT Deficiency 2: Inappropriate Deleting of Procedural Steps . . . . . . . 3 08.3 ORAT Deficiency 5: Questionable TS Interpretations .............. 4 08.4 ORAT Deficiency 6: Weaknesses in Corrective Action Program . . . . . . . 6 08.5 ORAT Observation 1: Operability Tracking Log Weaknesses . . . . . . . . . 7 08.6 ORAT Observation 2: General Operating Procedure Weaknesses . . . . . . 7 08.7 ORAT Observation 4: Administrative Controls for COMS Inoperabilities . 8 I
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08.8 ORAT Observation 6: Control Room Evacuatior. Drill Deficiencies .... 10 {
M2 Ma,intenance and Material Condition of Facilities and Equipment .......... 10
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l M 2.1 Review of Restart issues Related to Plant Equipment ............. 10 M4 Maintenance Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . 13 M4.1 Review of an improperly Installed Tornado Damper .............. 12 M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 M8.1 ORAT Deficiency 3: Inadequate Controls for Normalization ........ 14 M8.2 ORAT Deficiency 7: Temporary Equipment Storage Problem ....... 15 M8.3 ORAT Observation 3: Failure to Test PORVs from Main Control Roo M8.4 ORAT Observation 7: Latest Revisions of Procedures not Utilized . . . . 16 M8.5 ORAT Observation 8: Weaknesses in Surveillance Testing Procedure 16 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 E ORAT Deficiency 4: Improper Operation of Charging Pumps ....... 17 E ORAT Observation 5: Equipment Failures Challenging Operations . . . . 18 E ORAT Observation 9: 10 CFR 50.59 Screening Process . . . . . . . . . . . 18
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Report Details i
Summary of Plant Status l
This inspection covered a review of activities that took place during times that the reactors j in both units were in various modes of operation, including cold shutdown, hot shutdown, '
hot standby, startup, and power operations. The mode of operation and its applicability to each technical issue addressed is discussed, as necessary, in the body of the inspection repor l. Operations l l
O2 Operational Status of Facilities and Equipment i
O2.1 Review of issues identified by the Ooerational Readiness Assessment Team j (92901) l 1 Backaround Both units at South Texas Project were shut down in early February 1993 as a result of numerous broad scope problemc identified by the NRC and the license i The NRC issued a confirmatory action letter (CAL) to the Houston Lighting & Power l Company on February 5,1993. The CAL and a supplement, that was subsequently issued on May 7,1993, identified a number of issues that required resolution prior to either unit being restarted. A second supplement to the CAL was issued on October 15,1993, and identified additional restart issue ,
NRC Inspection Report 50-498/93-31;50-499/93-31, issued on October 15,1993, incorporated reviews of the CAL, its supplements, the diagnostic evaluation team report, items contained in the licensee's operational readiness plan, items ,
identified in NRC inspection reports, licensing actions, and selected NRC staff I actions resulting from the diagnostic evaluation. As a result of this evaluation, the inspection identified 16 restart issues that required resolution prior to the restart of j either unit. After extensive reviews and inspections, including an operational i readiness assessment team (ORAT) inspection led by the Special inspection Branch of the Office of Nuclear Reactor Regulation, the CAL was lifted for Unit 1 on ,
February 15,1994, and for Unit 2 on May 17,1994. Both units restarted shortly !
after the release from the respective CAL ',d have remained in normal operations, since that tim The ORAT had determined that the units were essentially ready for restar However, several commitments had been made by licensee management to perform certain corrective actions prior to restart of Unit 1. These commitments were documented in a letter from the NRC to HL&P dated January 27,1994. The corrective actions had been completed and reviewed by the NRC prior to restar Following the restart of Unit 1, the ORAT issued NRC Inspection Report 50-498/93-202; 50-499/93-202 to document the teams' findings. As a portion of the findings, the team documented seven deficiencies and nine
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-2-observations as being open and requiring additional NRC inspection. Although a majority of these items had been reviewed and inspected by the restart shift inspectors, the items had not been formally closed by specific docketed referenc Insoection Scoce During this inspection period, the inspectors reviewed each of the items that had remained open at the time of the ORAT. Restart era jnspection reports and docketed information supplied by the licensee were re' Mwed for previous corrective actions and documented inspection of the ORAT issues. Additional reviews of associated licensee corrective action reports were also conducted. As appropriate, the recent status of licensee programs and procedures were reviewe The inspectors reviewed each open ORAT issue to verify that: (1) those items considered at that time to require action prior to restart had specifically been reviewed for completion prior to the restart authorization; (2) as necessary, ,
appropriate enforcement actions had been taken; (3) the issues had been reviewed I sufficiently to resolve open safety issues in a timely manner; and (4) sufficient '
action by the licensee and inspection by the NRC had been conducted to bring the items to closur General Comments The inspectors closed 15 of the 16 ORAT open items as documented in the following subsections. All open ORAT items requiring corrective actions prior to I restart had been properly reviewed and resolved at that time. One noncited )
violation involving the normalization of safety-related instruments at shutdown, I identified by the ORAT inspectors, had not previously been clearly dispositione l The inspectors determined that all potential safety issues associated with the open ORAT item had been resolved, and that corrective actions and inspection were sufficiently complete to close each item.
08 Miscellaneous Operations issues (92901)
08.1 (Closed) Unresolved item (URI) 498:499/93202-01: Weaknesses in Controls for Monitorina Confiauration Manaaement During plant walkdowns, the ORAT noted that no mispositioned breakers or valves were found. However, they observed several minor configuration control discrepancies that had been promptly corrected by licensee personnel. In addition, a number of problems had been identified by licensee personnel related to the implementation of the equipment clearance order process. In response to the teams observations and comments, licensee personnel had identified that 33 station problem reports had been issued in the previous year referring to configuration control breakdowns. The team concluded that a programmatic weakness in
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3-l configuration management controls existed and ~was not being addressed by the licensee. .This programmatic weakness was documented as Deficiency 93-202-D !
This item was reviewed prior to plant restart as documented in Section 8.1 of NRC '
Inspection Report 50-498/94-009; 50-499/94-009. As documented, the inspector reviewed the results of a. task force evaluation of this subject, including the 33 station problem reports. The licensee had issued a corrective action plan and implemented immediate corrective actions. The item had remained open to further review the implementation of the action pla In a letter dated February 15,1994, the licensee documented that a long-term action plan had been developed and was being implemented. The review of the long-term action plan implementation and the licensee's configuration control and equipment clearance program implementation will continue to be reviewed by NRC inspectors as tracked by inspection Followup Item (IFI) 498;499/94025-02,
" Equipment Clearance Order Program implementation."
In addition, the ORAT inspectors had documented three specific configuration control problems:
(1) On January 12,1994, reactor coolant pumps were started without loop flow indication because plant instrumentation was not being correctly returned to service. The specifics of this event were reviewed as documented in Section M8.1 of this inspection repor (2) On January 15,1994, upon starting the Charging Pump 1 A, Valve CV-MOV-8348 opened in response to hydraulic pressure beneath the seat, resulting in two charging pumps being aligned and providing flow to the reactor coolant system. This alignment differed from that required by Technical Specifications Surveillance Requirement 4.1.2.3.2. The specifics of this event had been previously reviewed as documented in S.ection E of this inspection repor (3) On January 17,1994, an electrician performing a " clean and inspect" electrical preventive maintenance procedure on Cubicle N32 of Motor Control Center MCC2L1 was injured when he received an electric shock because of an inadequate equipment clearance order. The specifics of this j
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event had been previously reviewed as documented in Section 2.3 of NRC Inspection Report 50-498/93-055; 50-499/93-05 .2 (Closed) URI 498:499/93202-02: Inadeauate Controls for Deletina Procedural Steos The team observed that plant personnel were marking procedural steps as "N/A" and not performing the step without a documented justification as required by administrative procedure. This was documented as Deficiency 93-202-D i i
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-4-The inspectors reviewed the specific examples documented in the ORAT inspection report. Although, each example was indicative of weaknesses in the program, none of the examples indicated that violations had occurred. However, an example of inadequate usage of "N/A" had been identified by the resident inspectors and cited as a violation in NRC Inspection Report 50-498/94-009; 50-499/94-009. The violation was closed in NRC Inspection Report 50-498/95-027; 50-499/95-027. In the closure documentation, the inspector noted that Plant General Procedure OPGP03-ZA-0010, Revision 20, " Plant Procedural Adherence and Implementation and Independent Verification," had provided clear guidance for how to document a step as "not applicable."
08.3 (Closed) URI 498:499/93202-05: Questionable Technical Soecification interpretations (TSI)
The team had reviewed several documented licensee interpretations. Three examples had been identified where Technical Specification changes would have been more appropriate in addition, one example of considering the standby diesel generator operable with the associated handswitch in the " pull-to-lock" position was identified. The examples were documented as Deficiency 93-202-D The issue of TSis had been addressed by the diagnostic evaluation team as part of a broader area of confusing and conflicting management expectations and guidance provided to control room personnel. In NRC Inspection Report 50-498/93-031; 50-499/93-031 this issue was identified as IFl 498:499/93031-05. This IFl was closed as documented in NRC Inspection Report 50-498/94-006; 50-499/94-00 The inspectors had noted that potential TSis would be subjected to a formal routing and approval process. The inspector noted that the South Texas Project 19941998 Business Plan provided for a reduction in the number of open TSis. At the time of the ORAT inspection, 58 TSis had been in effect. During this inspection period, 25 TSis remained in effec The ORAT inspectors stated that three TSis reviewed appeared to provide clarification when a Technical Specification change would have been more appropriate. The inspectors reviewed the following items from the ORAT inspection report:
- TSI 132 permitted the use of a tolerance for the time constants used in the solid state protection system instrumentation for over temperature delta temperature and over power delta temperature setpoint This TSI remained open at the time of this inspection. The TSI documented i I
a letter from the nuclear steam supply system vendor to the licensee indicating that a 5 percent tolerance was acceptable in setting the time constants. The inspectors noted that Technical Specification 2.2.1 provided j specific values for the time constants without providing a tolerance as delineated in certain other specifications. However, in the documented
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-5-bases for this specification, the Technical Specifications stated that the set points were adjusted to be consistent with the " nominal valve." In addition, the bases documented that, " Inherent to the determination of the Trip Setpoints are the magnitudes for these channel uncertainties." Therefore, the inspectors concluded that the vendor that had established the time constants, could appropriately define the channel uncertainties associated with each time constant in the form of an acceptable toleranc Licensing department personnel stated that the improved Technical Specification submittal would more clearly resolve this questio * TSI 74 allowed temporary changes to component operability status of equipment, that had been declared inoperable to comply with a Technical Specification action statement, to f acilitate postmaintenance testing. This issue was resolved and clarified by Technical Specification Amendments 60 and 49. These amendments added Technical Specification 3.0.6 to clearly permit exiting action requirements to facilitate operability testin * TSI 54 allowed for the operability of the boration flow path, during shutdown, with valve emergency power not available. This associated Technical Specification was deleted and the guidelines transferred to the Technical Requirements Manual. At that time, the TSI was close * The ORAT had noted that one standing shift order allowed a standby diesel generator to be operable while in the pull-to-stop condition. The shift supervisor had referenced a similar TSI that permitted manual operator action in the place of an automatic function in explanation. Although the reactor was in Mode 5, the team inspectors had considered this to be a nonconservative interpretatio Licensee enDi neers documented that placing the standby diesel generators in the Pull-to-lock condition while in Modes 5 and 6 did not make the generator inoperable. In addition, Plant General Procedure OPGP03-ZA-0002, Revision 4, " Emergency Diesel Generetor," was revised to state that placing the diesel generator in the Pull-to-lock condition rendered the generator inoperable in Modes 1-4, onl * The ORAT inspectors had also stated that the interpretations did not appear to be kept up-to-date. Licensing personnel stated that the TSis had been reviewed and were now being maintained current. The inspectors reviewed the open TSis and found no examples of obsolete item The inspectors determined that although weaknesses had existed in the TSI program at the time of the ORAT, no violations were identified associated with
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6-those weaknesses. Licensee actions continued to reduce the number of TSis, and the issuance of the plant specific Improved Technical Specifications should incorporate and close the remaining open TSis.
08.4 (Closed) URI 498:499/93202-06: Weaknesses in Corrective Action Proaram Imolementation The ORAT reviewed the station problem report process and found that it was weak and vulnerable to error. The team identified significant deficiencies that did not receive a root-cause determination; dispositions that did not address all contributing causes; and adverse trend reports that did not address performance problems nor inefficient corrective actions. These weaknesses were documented as Deficiency 93-202-D6. The cover letter to the report, Ated March 7,1994, stated that "Although significant improvements have been maae with regard to the STP corrective action program, continued efforts are warranted to ensure that significant safety issues are promptly identified and thoroughly corrected, including the root cause of the event or equipment failure."
This issue was considered to be a portion of the review of Restart Issue 2, " Station j Problem Report Process, Threshold, Licensee's Review of Existing Reports for issues Affecting Operability and Safe Plant Operation." Despite the weaknesses noted in the ORAT report, this issue was considered resolved for the restart of j Unit 1 on February 1,1994, as documented in NRC Inspection j Report 50-498/93-054;50-499/93-054. This resolution was concurred upon by l
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the ORAT team, who stated that the corrective action program was weak, but improvements were in progress, and the program was adequate to support restar _
l During a review of the program adequacy prior to approval of the Unit 2 restart, I inspectors had reviewed the ORAT concerns as documented in NRC Inspection . '
Report 50-498/94-020; 50-499/94-020. The inspectors had determined that the licensee had enhanced the station problem reporting process and had fostered a culture that promoted problem identification and correction by line organization The licensee's initiatives had rest.ted in increased staffing, vigorous problem identification and ownership, ir,iproved training in causal analysis, and improved trending and oversigh The inspectors reviewed each weakness item identified in the ORAT. Although weaknesse: cleady existed, the station problem reports reviewed, based on the category assigned, had met the minimum criteria for evaluation defined in the licensee's program at that time. Additionally, the ORAT had not identified any repeat occurrences. Therefore, the inspectors concluded that no violations had been identifie in addition, on October 17,1994, a complete revision in the corrective action program and philosophy was implemented to further improve licensee response to reported conditions. This program and its effectiveness was reviewed, in detail, as
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documented in NRC Inspection Report 50-498/96-011; 50-499/96-011. This team *
concluded that the corrective action program was: strong; well-run; and capable of identifying, resolving, and preventing issues that degrade the quality of plant 3 i
operations or safet .5 (Closed) IFl 498:499/93202-08: Ooerability Trackina Loa Weaknesses :
i The ORAT commented that the operability tracking log was cumbersome and did not clearly distinguish between equipment status being tracked and equipment ;
inoperable in accordance with Technical Specifications. This item was documented ,
as Observation 93-202-0 Throughout the restart effort, inspectors reviewed the operability tracking log on a l daily basis. NRC inspection Report 50-498/94-009; 50-499/94-009 documented i that inspectors verified that Technical Specification limiting conditions for operation had been met utilizing the operability tracking log. In NRC Inspection ,
Report 50-498/94-027; 50-499/94-027, the inspectors documented a review of the 7 operability tracking log. Although this log may have been considered cumbersome ;
by individuals not familiar with it, the shift inspectors considered the log to be informative by providing additional information. In addition, licensed operators were routinely questioned concerning their knowledge of equipment status, and the operability tracking lo [
i Since that time, the operability tracking log has been replaced by the operability J assessment system. Specific guidance for use of the system was implemented by :
Plant General Procedure OPGP03-ZO-0039, Revision 9, " Operations Configuration r Management," Section 5.5. The resident inspectors have continued to review entries into this system on a routine basis. The system has proven to be effective (
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for the purpose of tracking system and component operabilit .6 (Closed) IFl 498:499/93202-09: Excessive Number of Outstandina General ,
Operatino Procedure Revisions The ORAT observed that implementation of requisite procedure revisions resulted in i numerous delays in activities during the restart in Unit 1 because procedures could l not be performed as written. This item was characterized as poor procedure quality and documented as Observation 93-202-02. The team noted that plant personnel had been aware of the need to follow procedures strictly, and correct them as .
I necessary. The team also recognized that a procedure improvement program was in progress and that a substantial reduction in the procedure feedback backlog had been mad ,
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A review of documentation produced during the restart effort indicated that ;
inspectors reviewed procedures and observed procedure usage on a daily basis, i The shift inspectors did not cite procedure quality as a problem area during the restart of either unit. The procedure enhancement effort has now been complete L
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8-Procedures have been routinely reviewed by the resident inspectors and quality has appeared to improve. The backlog of procedure feedback revisions for the general operating procedures has been maintained essentially at zero since the restar Changes to these procedures have been minor in nature and provided enhancemen .7 (Open) IFl 498:499/93202-11: Administrative Controls for Backuo Pressurizer Heaters while Cold Overc 1sure Mitiaation System is Out of Service The ORAT questioned whether adequate administrative controls were maintained over the pressurizer heaters as require 9 by the footnote to Technical Specification 3.4.9.3.c. The need for a review of the licensee's controls for cold overpressure protection was designated as Observation 93-202-0 . Technical Specification 3.4.9.3.c requires that the reactor coolant system be depressurized and vented through a vent of at least 2 square inches within 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> A footnote states that: "This action may be suspended for up to 7 days to allow functional testing to verify pilot-operated relief valve operability. During this test period, operation of systems or components which could result in an RCS mass or temperature increase will be administratively controlled..." The ORAT identified that under applicable conditions from January 13-15,1994 the pressurizer heaters were not tagged in the "off" position under an equipment clearance order, Scope (92901)
The inspector reviewed the control room logs taken at the time of the ORAT and the procedures for: pilot-operated relief valve testing; plant mode change; reactor cooldown; reactor heatup; and refueling. The inspector compared selected procedures against Technical Specification 3.4.9.3 on overpressure protection systems and the Updated Final Safety Analysis Report in addition, licensing documents addressing this Technical Specification were reviewe Observations and Findinas The inspectors reviewed the licensee's December 21,1990 submittal requesting that Technical Specification 3.4.9.3 be modified to add the subject footnote. In this submittal, the licensee defined the administrative controls that would be implemented to assure that the potential for a low temperature overpressure event was minimized during plant heatup and relief valve testing. One of the controls documented that:
"The Pressurizer Heaters will be inoperable during water solid operations to minimize the potential for a heat input overpressure transient."
The inspectors airo reviewed the safety evaluation by the Office of Nuclear Reactor Regulation related to Amendments 31 and 22 to the Technical Specifications.
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heaters inoperable was not addresse .
The inspectors reviewed the following procedures:
- Plant Operating Procedure OPOP03-RC-100, Revision 2, "RCS Vacuum Fill." .
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- Plant Operating Procedure OPOP02-RC-0003, Revision 9, .~illing and Venting the Reactor Coolant System."
- Plant Operating Procedure OPOP03-ZG-0001, Revision 13, " Plant Heatup." j
- Plant Surveillance Procedure OPSP03 RC-0010, Revision 2, " Pressurizer ;
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Power Operated Relief Valve Operability Test."
i e Plant Operating Procedure OPOP03-ZG-0007, Revision 13, " Plant Cooldown."
The inspector reviewed Procedure OPSP03-RC-0010 and noted that while Precaution Statement 4.8 referred to the footnote of Technical !
Specification 3.4.9.3, the procedure did not delineate any specific administrative controls on components that could result in a reactor coolant system mass or i temperature increase. The associated plant operating procedures required -
equipment clearance orders to danger tag components that could cause a reactor coolant system mass or temperature increase. However, during the pilot-operated relief vase testing, some components including the pressurizer heaters and the -
centrifugal charging pump did not have any specific administrative control The inspector found that the licensee did not have any specific administrative -
procedures for the extended action statement specified in the footnote of Technical Specification 3.4.9.3 and that the licensee relied on other procedures to minimize the potential for any transient that could actuate the overpressure relief syste The inspector found this practice to be weak. Additionally, although several associated procedures directed that the pressurizer heaters be turned off except when drawing a steam bubble, the heaters are not maintained inoperable nor danger i tagged in the off positio Licensee personnel and officials in the Office of Nuclear Reactor Regulation have agreed to research records associated with the issuance of Technical Specification Amendments 31 and 22. The purpose of this review will be to resolve the conflict
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between the submittal commitments and the safety evaluation report. in addition, this IFl will remain open until the following question is appropriately addressed:
What are acceptable administrative controls while the pilot-operated relief valves are inoperable? l i
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- 10-08.8 (Closed) IFl 498:499/93202-13: Slow Verification of Alternate Shutdown Panel Immediate Actions durina Drill The ORAT observed a simulated control room evacuation drill. Team members identified the following concerns: (1) operators were unable to use the plant pager from the alternate shutdown panel; (2) ambient noise levels in the alternate shutdown panel room were high; (3) labeling discrepancies were identified in the standby diesel generator rooms; and (4) the promptness of completing immediate actions was questioned. The licensee's consideration of these concerns was designated as Observation 93-202-0 The inspectors determined that the ability to use the plant pager from the auxiliary shutdown panel was now in place. In addition, licensed operators tested the capabihty on March 16,1997. However, licensee engineers stated that they had de: anined the noise levels in the panel rooms to be acceptable. The generic issue of dequate equipment labeling had been identified previously as IFl CJ8:499/91-019. This issue was closed as documented in NRC Inspection Report 50-498/94-035;50-499/94-035. The closure referenced specific NRC inspection of labeling on standby diesel generator subsystem The immediate actions of the control room evacuation procedure directed the operators to transfer control of safety system loads from the main control room to the auxiliary shutdown panel. To address the delays in the transfer of these loads, the operator requalification training was updated. The inspectors reviewed Simulator Scenario RST-X3, " Control Room Evacuation. This scenario included the transfer of loads from the main control room to the auxiliary shutdown panels and utilizing these panels to stabilize plant conditions. The new scenario was determined to adequately address the ORAT concern II. Maintenance
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M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Restart issues Related to Plant Eauioment (62707,71707) Insoection Scoce (71707)
As a result of the event described in Section M4.1.a of this inspection report, the inspectors reviewed the restart issues identified in the 1993 confirmatory action letter and its supplements. During routine resident inspection of plant system alignment and material condition, the inspectors reviewed the status of each of the restart issues that identified specific equipment-related commitment . _ . _ . _ _ .
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b. Observations and Findinas ,
As documented in the NRC inspection reports listed, the inspectors reviewed system alignment, surveillance testing, and material condition as necessary to ascertain that the restart issue related commitments were continuing to be me The following is a listing of the restart issues reviewed and the associated documentation of the inspections:
- Restart issue 1: Turbine-Driven Auxiliary Feedwater Pump Reliability and Testing Methodology l
- NRC Inspection Report 50-489/96-05;50-499/96-05 documented a ,
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flowpath verification of the steam-driven pump trains for both unit !
- NRC Inspection Report 50-489/96-06;50-499/96-06 documented the ,
observation of breaker maintenance for a system isolation valv l
- NRC Inspection Report 50-498/96-08;50-499/96-08 documented the observation of the inservice test of Auxiliary Feedwater Pump 2 ,
- NRC Inspection Report 50-498/97-01; 50-499/97-01 documented the :
verification of the discharge flowpath for all pumps in both unit * Restart issue 8: Adequacy of Fire Protection Computers and Software, the Licensee's Success in Reducing the Number of Spurious Fire Protection ,
System Alarms, and Other Fire Protection Hardware Problems l
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The inspectors routinely performed tours of the main control rooms in both units. During these tours, the inspectors verified the operability of the new fire protection computer and did not observe spurious nor continuous ,
alarming of system annunciators. In addition, NRC Inspection
Report 50-498/96-08; 50-499/96-08 documented the review of licensee corrective actions for missed operability testing of fire detection instrument * Restart Issue 11: Standby Diesel Generator Reliability
- NRC Inspection Report 50-489/96-05;50-499/96-05 documented a complete engineered safety features system walkdown conducted on Standby Diesel Generators 12 and 2 NRC Inspection Report 50-498/96-08; 50-499/96-08 documented the observation of the operability test of Standby Diesel Generator 1 NRC Inspection Report 50-498/96-09;50-499/96-09 documented the observation of a generator inspection on Standby Diesel Generator 11.
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.f e Restart issue 12: Essential Chiller Reliability NRC Inspection Report 50-498/96-04; 50-499/96-04 documented the flowpath verification of the Unit 1 Trains A and C er,sential chillers. In addition, the inspectors observed the replacement of the Chiller 123 seal package. The inspectors also routinely verified the cold weather operations alignment of the essential chillers during times of low essential cooling water temperature e Restart issue 14: Adequacy of the Licensee's Resolution of the Reliability and Operability of the Feedwater Isolation Bypass Valves These valves were routinely verified to be in good condition during plant tours. During this inspection period, the inspectors verified that all valves in both units were closed with an operable air supply and that the actuators appeared to be in good material conditio i e Restart issue 15: Tornado Damper issues The licensee's efforts to identify and correct problems associated with this I restart issue was within the scope of this inspection report. The inspectors j observed the condition of Damper 3V141VDA298. In aadition, the !
inspectors reviewed the licensee's engineering report concerning the condition of the other internal dampers and interviewed one of the l engineers. No discrepancies were identified, l l
The inspectors also reviewed Revision 1 to the licensee's response to Condition i Report 96-8858. As part of a generic review, licensee engineers also reviewed the l hardware-related restart issues. The licensee found that the equipment issues were fully resolved and no problems similar to the tornado damper issues were identifie c. Conclusions .
All hardware-related restart issues from the February,1993 confirmatory action letter and its supplements were reviewed. System walkdowns, maintenance and testing observations, and documentation reviews indicated that the licensee had met and continued to meet the restart issue commitments. Therefore, the inspectors determined that the failure to meet the restart issue commitment regarding Tornado Damper 3V141VDA298, was an isolated cas _ .-. . _ . _ . . _. _ . _ _ _ . . __ .__ - _ _ __ _ __ _
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I M4 Maintenance Staff Knowledge and Performance !
M4.1 Review of the Circumstances'Surroundina an Imoronerly installed Plant Ventilation l System Tornado Damoer (93702) !
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During the 1993 shutdown of both units, as discussed briefly in Section O2.1.a of l this inspection report, the failure to test and inspect plant tornado dampers had been identified as Restart issue 15. On January 29,1994, the licensee issued a i letter documenting the status of confirmatory action letter issues and stating that they intended to restart Unit 1. Attachment 1 to this letter discussed the closure ;
actions taken for Restart issue 15, stating that no actions remained to be performed f prior to Unit 1 restart. This issue was reviewed and considered resolved for restart as documented in NRC Inspection Report 50-498/93-42;50-499/93-4 !
As part of these closure activities, maintenance personnel had determined that i Tornado Dam ~. 1-210282 would not fully stroke because of an interference ,
between the linkage and a structural gusset. This issue was documented in !
LER 50-498/94-003. This event report documented that, "All Unit 1 tornado i dampers have been successfully stroked." Insoection Scope On July 11,1996, plant personnel identified that Tornado Damper 3V141VDA298,
" Containment Tendon Gallery Exhaust Damper," would not fully close. The {
inspectors reviewed the circumstances surrounding this occurrence, the safety significance of the damper's failure to function, and the significance of the licensee's previous comments regarding the functionality of plant Tornado Damper Observations and Findinas i
The craftsmen identified that the damper would not fully close during the performance of Preventive Maintenance Task MM-1-HC-9300514. The craftsmen noticed that the damper arm, attached to a constant force spring for testing purposes, contacted the damper support bracket when the damper was approximately 60 percent closed preventing further travel. Condition Report 96-8858 was written to document the condition. The as-found condition of l the damper on July 11, appeared to have been the as-installed confi0 uration from ]
original constructio i l The licensee stated that the personnel involved in the restart inspections were no l
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l longer on site. Licensee engineers surmised that the failure to identify this deficiency during prior testing was caused by the fact that it was not easy to visually verify this damper closed. it was not possible to visually verify that internal i dampers have changed state without opening the duct work. They speculated that
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during prior tests, maintenance craft personnel had depended on a closing sound to determine that the damper had closed rather than a visual inspection. During a close stroke the damper arm banged against the damper support bracket, came to a
, hard stop, and made the expected close sound, even though the damper was not
! actually close Licensee personnel responsible for preventive maintenance test development i
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thought that the dampers were being visually verified during stroking. Mana, Ament now surmises that the visual inspection of damper condition was performed separately from the stroking operation. Therefore, previous preventive maintenance activities had been inadequate to identify the improper installation of the dampe As remedial corrective action, an engineer and a qualified maintenance technician l reinspected all external linkages on internal dampers (dampers completely enclosed I
by the duct work) to verify no other cases of undetected binding existed.
l The licensee's corrective actions were appropriate to the circumstances. Generic i
reviews of both the tornado dampers and other hardware-related restart issues were conducted. However, the inspectors determined that a statement made in LER 50-498/94-003 was not accurate. Tornado Damper 3V141VDA298 could not have been successfully stroked prior to the restart of Unit 1 because of its as-installed configuration. Although, this erroneous information was in violation of 10 CFR 50.9, this licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic Conclusions Previous preventive maintenance activities had been inadequate to identify the improper installation of the tendon gallery exhaust tornado damper. Coirective actions taken following the identification of the construction deficiencies were thorough and involved generic reviews of other hardware-related restart issue However, a statement documented in LER 50-498/94-003 was erroneous, in that, the tendon gallery exhaust tornado damper could not have been successfully stroked prior to the restart of Unit 1. This licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vil of the NRC Enforcement Polic M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) URI 498:499/93202-03: Inadeauate Controls for Normalization of instrumentation The team identified several weaknesses associated with the implementation of Plant
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Maintenance Procedure OPMP08-SP-0001, Revision 2, "RPS/ESF System
- Normalization." These weaknesses resulted from plant personnel not understanding
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t he test equipment and jumpers installed on solid-state protection equipment while the plant was in Mode 5 and 6 to simulate 100 percent power on control board
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-15-instrumentation. The issue of inadequate controls for normalization of plant instrumentation was designated as Deficiency 93-202-D On January 24,1994, licensee personnel documented an event associated with these weaknesses in Station Problem Report 940088. During this event, operators failed to follow the requirements of Plant Operating Procedure OPOP02-RC-0004, Revision 6, " Operation of Reactor Coolant Pump." Therefore, operators failed to identify that reactor coolant system flow instrumentation was inoperable during the filling and venting of the reactor coolant system. As a result of this event, Procedure OPMP08-SP-0001 was revised to include instructions on the partial removal of the normalization harness. This revision included tracking of configuration change The failure to properly implement an operating procedure is a violation of Technical Specification 6.8.1.a. This event revealed and licensee-corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. The inspectors reviewed Revision 5, to Procedure OPMP08-SP-0001 as well as Revision 8 to Procedure OPOP02-RC-0004, and Plant General Procedure OPOP03-ZG-0001, Revision 14, " Plant Heatup." The inspector verified that the stated corrective actions were included in the revision to Procedure OPMP08-SP-0001. The inspector also verified that the revisions to Procedures OPOP02-RC-0004 and OPOP03-ZG-0001 required the shift supervisor to verify procer status of normalization before proceeding. The inspectors reviewed the licensce's corrective action program database of events and conditions occurring over a 2-year period beginning October 17,1994. No occasions were documented in which configuration controls of the normalization harness were inadequate or utilizing the harness had resulted in a plant even M8.2 (Closed) URI 498:499/93202-07: Inadeauate Controls for Temocrary Eauioment Storaae The team observed that a portable eyewash station had been staged on the floor of a vital battery room. The team questioned whether the staging of this equipment was in compliance with Plant General Procedure OPGPO3-ZA-0098, Revision 0,
" Station Housekeeping." This question was documented as Deficiency 93 202-D During the ORAT inspection, the team reviewed and documented actions taken by the licenseo to correct this concern. Throughout the restart efforts, inspectors routinely toured plant spaces and found that housekeeping practices were generally being adhered to. In addition, the inspectors routinely verified that housekeeping practices were adequately implemented via the core NRC inspection program. The inspectors determined that the eyewash station being staged in a vital battery room had not been in violation of station housekeeping procedures. The station had been staged for personnel protection and operational convenience while the performance
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-16-of the permanent installed eyewash station had been degraded. In addition, licensee engineers stated that the station's presence did not pose an operability concern for the vital battery.
M8.3 [QJosed) IFl 498:499/93202-10: Failure to Stroke Relief Valves from the Main Control Board The ORAT had questioned the validity of pressurizer pilot-operated relief valve testing because the valves were routinely stroked from the auxiliary shutdown panel. This electrically bypassed the main control panel manual actuation circuitr This was documented as Observation 93-202-0 This issue was fully reviewed prior to plant restart as documented in Section 6 of NRC Inspection Report 50-498/93-055;50-499/93-055. The inspector had determined that Technical Specification surveillance requirements were being met, and that licensee corrective actions hrd been acceptable.
M8.4 (Closed) IFl 498:499/93202-14: Latest Revisions of Work Procedures Not Utilized The ORAT noted several examples of surveillance tests performed utilizing an incorrect revision of the test procedures. The team indicated that although the licensee's procedural controls and training program appeared to be adequate to ensure use of the current revision of appropriate documents, the identified occurrences indicated the need for continued licensee attention. This item was documented as Observation 93-202-0 The inspectors reviewed the licensee's condition reporting database for reports of the use of incorrect revisions of surveillance test procedures. No occurrences of incorrect revision use were identified in the past twelve months. Additionally, the inspectors routinely verified that the current revisions of surveillance procedures were in use during routine surveillance test observations. No revision discrepancies were identified.
M8.5 (Closed) IFl 498:499/93202-15: Weaknesses in Surveillance Testina Procedures The ORAT noted several examples of procedural inadequacies that could have resulted in work performance problems. The team indicated that these problems should be corrected by the licensee's procedure upgrade program. This item was documented as Observation 93-202-0 During the ORAT inspection, the team reviewed and documented actions taken by the licensee to correct each of the examples noted. These corrective actions included revising the surveillance procedures writer's guide to assist in correcting similar generic problems during the surveillance procedure enhancement progra In addition, the adequacy of surveillance procedures was routinely reviewed throughout the restart efforts. Most notably, as documented in NRC inspection
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l Report 50-498/94-017; 50-499/94-017, the inspectors reviewed and observed the
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performance of 12 surveillance procedures. The quality of the procedures had been
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Finally, as documented in NRC Inspection Report 50-498/95-023; 50-499/95-023,
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Violation 498/94010-01 remained open to track the generic issue of surveillance procedure adequacy and the completion of the licensee's long-term surveillance
- procedure enhancement program. Therefore, this IFl is administratively close .
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l Ill. Enaineerina E8 Miscellaneous Engineering issues (92903)
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! E8,1 (Closed) URI 498:499/93202o4: Imoroper Ooeretion of Two Centrifuaal Charaina i Pumos '
t The team observed that during the start of Centrifugal Charging Pump 1 A for i testing, reactor coolant pump sealinjection flow inadvertently increased to greater i than 20 gpm to each pump. The failure to maintain the discharge bypass valve ;
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closed had appeared to be in violation of Technical Specification 3.1.2.3. This ;
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issue was documented as Deficiency 93-202-D l
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- This event had been reviewed at that time by the resident inspectors as
i documented in Section 2.4 of NRC Inspection Report 50-498/93-055; i 50-499/93-055. The inspectors documented that initial corrective actions had been reviewed at that time. The acceptability of these corrective actions was also
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documented in Section 8.2 of NRC Inspection Report 50-498/94-009;
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In addition, the licensee submitted LFR 498/94-002, in accordance with 10 CFR Section 50.73, addressing the issues that resulted in this event. The LER was l
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l reviewed and closed as documented in NRC Inspection Report 50-498/95-027; l 50-499/95-027. In that report, the inspectors documented the acceptable i completion of licensee corrective actions. This eveat was reported as a violation of
Technical Specification 3.1.2.3. However, all the criteria of this specification f
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appeared to have been met. The event had been caused by a hydro-pneumatic transient not previously experienced or understood by licensed operator Therefore, the previous inspectors had determined that, because the valve was closed when the pump was energized, a notice of violation was not warranted.
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-18-E (Closed) IFl 498:499/93202-12: Eauipment Failures Challencina Operations Personnel The team noted that plant material condition was generally good. However, the inspectors observed a number of equipment failures, and concluded that these failures were unnecessarily challenging the operating staff. This conclusion was documented as Observation 93-202-0 This issue was completely bounded by Restart issue 3, " Service Request Backlog, including Reduction Accomplished During the Current Outages and the Licensee's Review of Outstanding Service Requests for issues Affecting Equipment Operability, Safe Plant Operation, and Operator Work-arounds." This issue was considered resolved for restart as documented in NRC Inspection Report 50-498/94-008; 50-499/94-008. A related item IFl 498;499/94031-47: "lnoperable Automatic Functions and Main Control Board Work Items," remained open to assess the attainment by the licensee of the goal to have no significant impact on system operability or operator burden prior to restart. This item was further reviewed and closed as documented in NRC Inspection Reports 50-498/94-017; 50-499/94-017 and 50-498/95-023; 50-499/95-023.
E (Closed) IFI 498:499/93202-16: Inconsistencies in Performance of 10 CFR 50.59 Screenina Process The team reviewed multiple plant modification design packages to verify the completeness and engineering adequacy of the unreviewed safety question
- evaluations. In two packages, the inspectors identified that an unreviewed safety question evaluations had not been performed in accordance with 10 CFR 50.5 The appropriateness of the licensee's definition of a change to the safety analysis report was questioned. This was documented as Observation 93 202-0 The inspectors reviewed the two specific examples documented by the ORAT. In neither case had the changes constituted an unreviewed safety questio Therefore, no safety significance was attributed to the finding On a more generic basis, as documented in NRC Inspection Report 50-498/94-027; 50-499/94-027, inspectors reviewed multiple design change packages for the adequacy of the unreviewed safety question evaluations. The inspectors had ,
concluded that, with one exception, the screening determinations had properly l ensured that the requirements of 10 CFR 50.59 were being met. The one j exception was not cited as a violation because the example had no safety -
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ATTACHMENT !
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SUPPLEMENTAL INFORMATION I
PARTIAL LIST OF PERSONS CONTACTED l
Licensee t l
T. Cloninger, Vice President, Nuclear Engineering W. Cottle, Executive Vice President and General Manager, Nuclear J. Groth, Vice President, Nuclear Generation S. Head, Licensing Supervisor B. Masse, Plant Manager, Unit 2 G. Parkey, Plant Manager, Unit 1 D. Schulker, Compliance Engineer l
INSPECTION PROCEDURES USED IP 62707: Maintenance Observations IP .71707: Plant Operations IP 92901: Followup - Plant Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 93702j Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED. CLOSED. AND DISCUSSED One,1ed 498/96022-01 NCV" Reactor Coolant Pumps Started without the Flow Instrumentation Required by Procedures 498/96022-02 NCV* Erroneous information regarding Tornado Damper Testing l Reported in an LER !
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Closed .
498/96022-01 NCV* Reactor Coolant Pumps Started without the Flow Instrumentation Required by Procedures 498/96022-02 NCV" Erroneous information regarding Tornado Damper Testing l
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Reported in an LER l
498:499/93202-01 URI Weaknesses in Controls for Monitoring Configuration '
Management
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498:499/93202-02 URI Inadequate Controls for Deleting Procedural Steps (D2) l
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-2-498:499/93202-03 URI Inadequate Controls for Normalization of Instrumentation 498;499/93202-04 URI -Improper Operation of Two Centrifugal Charging Pumps 498 499/93202-05 URI Questionable Technical Specification Interpretations 498:499/93202-06 URI Weaknesses in Corrective Action Program implementation 498;499/93202-07 URI Inadequate Controls for Temporary Equipment Storage 498:499/93202-08 IFl Operability Tracking Log Weaknesses 498;499/93202-09 IFl Exce- .re Number of Outstanding General Operating Procedure Ret ans 498;499/93202-10 IFl Failure to Stroke Pilot-operated Relief Valves from Main Control Board 498;499/93202-12 IFl Equipment Failures Challenging Operations 498:499/93202-13
IFl Slow Verification of Alternate Shutdown Panel immediate Actions during Drill 498:499/93202-14 IFl Latest Revisions of Work Procedures not Utilized
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498:499/93202-15 IFl
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Weaknesses in Surveillance Testing Procedures 498:499/93202-16 IFl Inconsistencies in Performance of 10 CFR 50.59 Screening Process Discussed 498;499/93202-11 IFl Administrative Controls for. Backup Pressurizer Heaters while Cold Overpressure Mitigation System is Out of Service 498:499/94025-02 IFl Equipment Clearance Order Program implementation 498/94010-01 VIO Track the Completion of the Surveillance Procedure Enhancement Program
- The noncited violations identified in this report require no further NRC review and are considered both opened and closed in this inspection repor .
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LIST OF ACRONYMS USED '
b CAL confirmatory action letter HL&P {
l Houston Lighting & Power Company j IFl inspection followup item !
l LER licensee event report
l NCV noncited violation NRC U.S. Nuclear Regulatory Commission ORAT operational readiness assessment team ,
- RCS reactor coolant system i STP South Texas Project
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TSI Technical Specification interpretation
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URI unresolved item VIO violation
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