ML20129B539
| ML20129B539 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/22/1985 |
| From: | Carpenter D, Carpenter G, Constable G, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20129B383 | List: |
| References | |
| 50-198-85-1, 50-498-85-01, 50-498-85-1, 50-499-85-01, 50-499-85-1, NUDOCS 8507290182 | |
| Download: ML20129B539 (8) | |
See also: IR 05000101/2002028
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-498/85-01
CP:
CPPR-128 and 129
50-499/85-01
Dockets: 50-498
50-499
Licensee: Houston Lighting & Power Company (HL&P)
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P. O. Box 1700
Houston, Texas 77001
Facility Name: South Texas Project (STP), Units 1 and 2
Inspection At:
Inspection Conducted: January 1 - February 28, 1985
7!"-/4ff
Inspecto
D. IK-Mpehter, Resident Inspector
Date
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7[2/75'
Approved:-
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unta , Project Section C
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Reactor Project Branch 1
Jnspection Summary
Inspection Conducted January 1 - February 28, 1985 (Report 50-498/85-01;
50-499/85-01)
Areas Inspected: Routine, unannounced inspection included:
(1) site tours;
(2) review of revised startup administrative instructions (SAI); (3) review of
generic test procedures; (4) reconciliation of proposed Final Safety Analysis
Report (FSAR), Chapter 14 Revision; (5) review of startup training files;
(6) training simulator; and (7) operator cold license training. The inspection
involved 235 inspector-hours onsite by the NRC inspector.
Results: Within the scope of this inspection, one violation was identified.
Failure to properly follow procedures (8501-01) in paragraph 6.
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
R. Balcom, Reactor Operations Supervisor
- G. Parkey, Technical Support Superintendent
J.'Hughes, Construction Superintendent
D. Cody, Training Manager
- R. Daly, Startup Manager
- S. Dew, Deputy Project Manager
L. Fotter, Startup Training Supervisor
- J. Goldberg, Vice President, Nuclear Engineering and Construction
- J. Green, Operations Quality Assurance (QA) Manager
.G. Jarvela, Health / Safety Service Manager
T. Jordan, Site QA Manager
- W. Kinsey, Plant Manager
M. Ludwig, Maintenance Manager
- M. McBurnett, Licensing Supervisor
- G. Oprea, Jr., Executive Vice President
A. Peterson, Startup Engineer Special Projects
- J. Westermeier, Project Manager
- F. White, Site Licenting
- J. Williams, Site Manager
- B. Franta, Manager, 3taff Training
Other Personnel
Bechtel Power Corporation (Bechtel)
- J. Downs, Deputy Manager of Construction
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- L. Hurst, Project QA Manager
A. Priest, Site Manager
Ebasco Services, Inc. (Ebasco)
- C. Hawn, Quality Program Site Manager
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Westinghouse Electric Company (Westinghouse)
- A. Hogarth, Site Manager
In addition to the above personnel, the NRC inspector held discussions
with additional licensee, Bechtel, and other contractor personnel during
this inspection.
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- Denotes those individuals attending one or more management meetings during
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the inspection period.
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2.
Site Tour
During this reporting period, routine tours of the site were conducted by
the NRC inspector.
In addition to the general housekeeping activities and
cleanliness of the facilities, specific attention was given to areas where
safety-related equipment is installed, stored, and where activities were
in progress involving safety-related equipment. These areas were
inspected to ensure that:
Work in progress was being accomplished in accordance with approved
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procedures.
Special precautions for protection of equipment were being
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implemented, where required, and additional cleanliness requirements
were adhered to, where required.
General plant cleanliness was being maintained with trash and
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construction debris being removed in a timely manner and unused
construction material was being properly stored.
The areas inspected included:
Units 1 and 2
Reactor containment buildings, mechanical / electrical auxiliary buildings
(MEABs), fuel handling buildings, diesel generator buildings, and the
safety-related equipment areas within the turbine generator buildings.
The general plant cleanliness was acceptable. Areas of concern that were
noted to the licensee were cleaned and placed in order in a timely manner.
Pockets of trash, construction debris, and construction material not being
used continue to appear in various locations that are out of the main
stream of activity.
Such areas as small rooms, cells, cable spreading
areas, pipe trenches, and cableways in the reactor containment and the
MEAB need to be given continuous attention in order to maintain general
plant cleanliness.
The NRC inspector observed a continuation of efforts to upgrade the
physical protection of in plant stored equipment.
New plastic wrap was
observed being installed on the MEAB equipment. Heat trace and temporary
air filters were checked and found to be in place and functioning.
Site
Reservoir, essential cooling pond, warehouses, laydown areas, welder
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qualification area, and heavy equipment storage area.
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With regard to the above areas, the NRC inspector confirmed the following:
Safety-related and storage areas were free from accumulations of
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trash, refuse, and debris.
Work areas were clean and orderly.
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Tools, equipment, and material were returned to their proper storage
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locations when no longer in use.
The NRC inspector observed construction and material handling activities
at the essential cooling pond pump house to be orderly and acceptable.
Equipment and material movement and storage was observed at the warehouse
and laydown complex. All activities were being conducted in a safe,
effective manner.
No violations or deviations were identified.
3.
Review of Reissued Startup Administrative Instructions (SAI)
As a result of the replacement of the startup manager, the entire "Startup
Administrative Instruction Manual" was revised and reissued in toto.
This
revision resulted in a reduction in the number of SAIs from 3T to 19.
The
NRC inspector reviewed the revised SAIs against the old SAIs, FSAR,
Chapter 14 and the operations QA plan. This review was conducted to
determine whether there had been a reduction in commitments made in the
FSAR or other issued documents. The procedures reviewed and comments are:
SAI 1, "Startup Manual Use and Control," Revision 0 - No Comment
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SAI 2, "Startup Organization," Revision 0, Section 4.1.2 - Although
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the responsibilities of the startup manager are directly quoted from
the FSAR, Chapter 14, there are some direct responsibilities assigned
to him under SAI 6, " Document Control," Section 4.1, dealing with the
test records center that are not noted here.
SAI 3, "Startup Quality Assurance Plan," Revision 0 - Section 5.1.1
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states, "The organization and responsibilities of the person
performing quality functions during the startup program are described
in SAI 2."
Contrary to the above, no mention of this subject is in
SAI 2.
SAI 4, " Equipment Clearance," Revision 0 - Section 5.0, paragraph 2
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states, " Components that have been removed from their permanent
location for bench testing are not required to be danger tagged."
While this may be true, it is misleading in that danger tags may be
needed to protect personnel from the " hole" left when equipment is
removed, i.e., if a relay is removed, the circuit that would have
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supplied power to that unit should be tagged. This SAI really says
nothing except to use Plant Procedure PGP3-7.0-1, " Equipment
Clearance."
SAI 5, " Release For Test," Revision 0 - There is no requirement on
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the jurisdiction tags / stickers to identify what component / system
specifically is being turned over. While this is not a requirement,
specific identification would reduce major error.
SAI 6, " Document Control," Revision 0, Section 5.1.3(2) - The
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" Official Test Copy" stamp should be in place prior to starting the
test. Same comment for Section 5.3.3(2).
5.1.3(f) - Add "startup' between " responsible" and " Level III "
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5.2.5(b) - Define " test package." What elements are required to
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be present?
SAI 7, " Preventive Maintenance-Program," Revision 0, Section 5.1 -
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Additionally, the construction preventive maintenance cards should be
reviewed to determine if the component was in fact maintained as
required.
SAI 8, " Master Completion List," Revision 0, Section 5.3.2 - Does the
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record center maintain a record copy of closure documents?
SAI 9, " Control of Measuring and Test Equipment," Revision 0,
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Section 5.1.4 - What is the status of the test being conducted at
the end of this section?
SAI 10, " Indoctrination and Certification of Test Persor.nel,"
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-Revision 0 - No comment.
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SAI 11. "Startup Work Request," Revision 0 - No comment.
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SAI 12, " Field Change Request and Startup Field Reports," Revision 0 -
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No comment.
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SAI 13, " Configuration Control Package," Revision 0 - No comment.
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SAI 14, " Temporary Alteration Control," Revision 0 - Section 5.1
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states, ". . . do not require temporary alteration tagging or
logging . . ." while the " note" states, ". . . shall tag both the
component and location . . ." Reconcile these two statements.
Section 5.2.1 - Does this mean that activities conducted under 5.1 do
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not have to be orange? Reconcile with Operations QA Plan 11.0,
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Section 6.4.8.
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SAI 15, " Material Requisition and Vendor Services," Revision 0 - No
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comment.
SAI 16, " Review of Startup and Operating Experience," Revision 0 - No
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comment.
SAI 17, " Prerequisite Testing," Revision 0 - Page 8 is not
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consistent with format requirements of SAI 1, Section 1.1.1 and
1.1.3.
SAI 18, "Preoperational Testing," Revision 0 - Define what goes into
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the chronological log and test packages.
SAI 19, " Acceptance Testing," Revision 0 - No comment.
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General Comments
Not all references used in the body of the text are listed in
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Section 3.0.
The "old" set of SAls contained information in regard to the joint
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test group, cleanliness and housekeeping, turnover to operations,
discussion on how to prepare test procedures,Section XI work, and
various other activities. Where are these subjects now covered?
With the revision and reissuance of the SAIs, a large amount of user
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guidance and "how to" information has been eliminated from the SAIs.
How and where is this guidance to be provided to the startup
personnel?
The above specific and general comments are provided as information and
documentation of the NRC inspector's review of the SAIs.
No violations or deviations were identified.
4.
Review of Generic Test Procedures
The NRC inspector reviewed several issued and revised generic test
procedures used in component testing during the prerequisite testing
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phase. The tendency seems to be toward shortening the procedures and
eliminating the "how to" information. At this point it is hard to
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determine if these procedures are adequate for component testing of
safety-related systems. At this time there is no safety-related testing
being performed.
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No violations or deviations were identified.
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Reconciliation of Proposed Final Safety Analysis Report, Chapter 14
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Based on a decision to overhaul the startup test program, the licensee
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proposed a revision to Chapter 14 of the South Texas FSAR.
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revision constituted a major rewrite with the elimination of much specific
guidance as to responsibilities and test description information. The NRC
inspector re. viewed this draft and discussed its impact on testing. The
licensee has agreed to review the proposed draft and insure that no
reduction in commitments to NRC has occurred. The revision will deal
mainly with how the startup group is organized and where the various
responsibilities lie.
No violations or deviations were identified.
6.
Review of Startup Training Files
The NRC inspector reviewed the training files of senior startup personnel.
This review included work history, QA indoctrination, startup training,
startup required reading list, and other required records.
Of the five startup files reviewed, two were complete and acceptable. One
file was missing a supervisor's signature and in the same file a signature
was placed in the wrong location. One file had no documentation of the
required QA lectures in the file, but the training department index
indicated he had attended. The startup manager had not attended the
required QA indoctrination lecture, a requirement for conducting Startup
Activities / Operations QA Plan 4.0, Section 6.2.1.
The above is considered a violation of Level V Severity (8501-01).
7.
Training Simulator
The NRC inspector made a tour of the STP training simulator currently
undergoing assembly and acceptance testing in Bay City, Texas. The
simulator was fabricated based on a pre-TMI control room configuration.
Since the order was placed, a significant redesign of the control room
appearance has been completed.
The decision by the licensee was to accept
the original simulator design, complete acceptance testing (the logics
remain nearly the same), and then perform the hardware reconstruction.
All activities are scheduled to be completed by the end of 1985 with the
redesigned simulator in place and tested, ready for operator training at
the emergency operations facility (EOF) adjacent to the site.
No violations or deviations were identified.
8.
Operator Cold License Training
The NRC inspector attended several hours of cold license training. These
sessions were on fundamental and nonsafety systems. Class size was
20 students. There was good class participation and the instructor took
time to answer all questions completely. The session did not proceed till
all students were satisfied and the instructor was satisfied, based on
oral questioning by the instructor on the subject just completed.
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The lesson plans and hand-outs were rough drafts and marked up based on
design changes. The formal training manuals are about 6 months away.
Some fundamentals (heat transfer, etc.) were taught using B&W once-
through steam generator.
No violations or deviations were identified.
9.
Exit Interviews
Exit interviews were held periodically with the licensee management
personnel during the course of this inspection. Those attending one or
more of the meetings are denoted in paragraph 1.
At these meetings, the
scope and findings of the inspection were presented.