ML20129B539

Insp Repts 50-498/85-01 & 50-499/85-01 on 850101-0228. Violation Noted:Startup Personnel Training File Missing Supervisor Signature & Signature Placed in Incorrect Location on Same File

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: ML20129B379 ML20129B478 ML20129B539
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

Text

.

I

,

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)

P. O. Box 1700

Houston, Texas 77001

Facility Name: South Texas Project (STP), Units 1 and 2

Inspection At: STP, Matagorda County, Texas

Inspection Conducted: January 1 - February 28, 1985

Inspecto

D. IK-Mpehter, Resident Inspector

7!"-/4ff

Date

'

Approved:- _

.% , _ . m , unta , Project Section C

7[2/75'

D6te /

.

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.

8507290182 850723 "

PDR ADOCK 05000498

<

G PDR<

.

_2_

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

l *L. Hurst, Project QA Manager

A. Priest, Site Manager

Ebasco Services, Inc. (Ebasco)

• C. Hawn, Quality Program Site Manager

j- 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.

.

• Denotes those individuals attending one or more management meetings during

! the inspection period.

,

-

'

.

-3-

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

procedures.

. Special precautions for protection of equipment were being

implemented, where required, and additional cleanliness requirements

were adhered to, where required.

. General plant cleanliness was being maintained with trash and

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

qualification area, and heavy equipment storage area.

l

'

.

l

C

,

.

-4-

With regard to the above areas, the NRC inspector confirmed the following:

. Safety-related and storage areas were free from accumulations of

trash, refuse, and debris.

. Work areas were clean and orderly.

. Tools, equipment, and material were returned to their proper storage

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

. SAI 2, "Startup Organization," Revision 0, Section 4.1.2 - Although

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

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

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

.,

,

-

.

-5-

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

the jurisdiction tags / stickers to identify what component / system

specifically is being turned over. While this is not a requirement, l

specific identification would reduce major error.

. SAI 6, " Document Control," Revision 0, Section 5.1.3(2) - The

" 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 "

. 5.2.5(b) - Define " test package." What elements are required to

be present?

. SAI 7, " Preventive Maintenance-Program," Revision 0, Section 5.1 -

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

record center maintain a record copy of closure documents?

. SAI 9, " Control of Measuring and Test Equipment," Revision 0,

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,"

-Revision 0 - No comment.

i

. SAI 11. "Startup Work Request," Revision 0 - No comment.

. SAI 12, " Field Change Request and Startup Field Reports," Revision 0 -

l- No comment.

.

1

. SAI 13, " Configuration Control Package," Revision 0 - No comment.

,

. SAI 14, " Temporary Alteration Control," Revision 0 - Section 5.1

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

i

not have to be orange? Reconcile with Operations QA Plan 11.0,

Section 6.4.8.

I

I

,

.

-6-

. SAI 15, " Material Requisition and Vendor Services," Revision 0 - No

comment.

. SAI 16, " Review of Startup and Operating Experience," Revision 0 - No

comment.

. SAI 17, " Prerequisite Testing," Revision 0 - Page 8 is not

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

the chronological log and test packages.

. SAI 19, " Acceptance Testing," Revision 0 - No comment.

General Comments

. Not all references used in the body of the text are listed in

Section 3.0.

. The "old" set of SAls contained information in regard to the joint

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

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

i

procedures used in component testing during the prerequisite testing

l phase. The tendency seems to be toward shortening the procedures and

I

eliminating the "how to" information. At this point it is hard to

determine if these procedures are adequate for component testing of

safety-related systems. At this time there is no safety-related testing

,

being performed.

!

No violations or deviations were identified.

i

S. Reconciliation of Proposed Final Safety Analysis Report, Chapter 14

,

Revision

!

l Based on a decision to overhaul the startup test program, the licensee

i proposed a revision to Chapter 14 of the South Texas FSAR. This

l

,

e

m

.

-7-

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.

-

.-

-8-

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.