ML20138A954

Insp Repts 50-498/85-15 & 50-499/85-14 on 850801-0930. Violation noted:100% Verification of Status of Equipment Greasing Revealed 99 Out of 234 Pieces of safety-related Equipment Had Maint Discrepancies

ML20138A954
Person / Time
Site:	South Texas
Issue date:	02/18/1986
From:	Breslau B, Carpenter D, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138A924	List: ML20138A919 ML20138A930 ML20138A954
References
50-498-85-15, 50-499-85-14, NUDOCS 8603200221
Download: ML20138A954 (7)

See also: IR 05000498/1985015

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/85-15 Construction Permits: CPPR-128 and

50-499/85-14 CPPR-129

Dockets: 50-498 and 50-499

Licensee: Houston Lighting & Power Company (HL&P)

P. 0.. Box 1700

Houston, Texas 77001

Facility Name: South Texas Project, Units 1 and 2

Inspection At: South Texas Project, Matagorda County, Texas

Inspection Conducted: August 1 - September 30, 1985

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Inspectors: __

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D7R. Cariieiiter, Resident Inspector Date

/' Project Section C, Reactor Projects Branch

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'B. A. Breslau, Project Inspector Dhte'

Project Section C, Reactor Projects Branch

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Approved: T 't fC6nstable, Chief Date

Project Section C, Reactor Projects Branch

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8603200221 860311 ,

PDR ADOCK 05000498  !

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Inspection Summary

Inspection Conducted August 1 - September 30, 1985 (Report 50-498/85-15;

50-499/85-14)

Areas Inspected: Routine, unannounced inspection included: site tours, -

licensee action on previously identified items, permanent plant maintenance

and startup and maintenance activities. The inspection involved 199 inspection-

hours onsite by two NRC inspectors.

Results: Within the scope of this inspection, one violation was

identified and is discussed in paragraph 4.

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1. Persons Contacted'

Principal Licensee Employees

E. Hill'.- Project Compliance Engineer

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'* R.1Daly Startup Manager

• 'S. Dew, Deputy Project Manager ^

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• T. ~ J. Jordan,' Project .QA Manager '

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• W._ H.'Kinsey, Plant Manager

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• A.~J. Peterson, Startup

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• J. T. Westermeier, Project Manager

• F. White, Lead Project Compliance Engineer

• R. R. Hernandez, Supervisor, Project Compliance

K. O'Gara, Project Compliance Engineer -

F. . Alkov, Material Control Supervisor

• L. Dolan,' Project. Compliance Engineer

• D. R. Keating,.0perations QA General Supervisor

• 'R. C. Arthurs, Project QA General Supervisor

• M. S. Whittaker_, Metrology Laborato'ry.. Supervisor

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Other Personnel

Bechtel Power Corporation (Bechtel)

• N. A. Joonejo, Engineering Group Supervisor -

• L'. Hurst, Project QA Manager

• R. D. Bryan, Deputy Project Manager, Construction

• R. Schulman, Site Civil Engineer

• J. B. Gatewood, Project QA Engineer

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• R. H. Medina, Lead QA Engineer

• J. T. Minor, Deputy Site Engineering Manager

M. H. Alexander, Materials Manager

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'Ebasco Services, Inc. (Ebasco)

• A. M. Cutrona, QA Manager .

• R. M. Zaist, Construction Manager

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Westinghouse Electric Company (Westinghouse)

• A. Hograth, Site Manager ,

• Denotes those individuals attending the exit interview conducted on

Octobe'r 3, 1985.

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2.' Site Tours

'The NRC inspector conducted site tours both independently and

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accompanied by licensee and contractor personnel. These tours were

made in order to assess-the protection of inplace safety-related plant

, equipment, plant' status and to observe construction, testing and

maintenance' activities. The areas toured included, Unit 1: Mechanical and

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Electrical Auxiliary Building (MEAB), Diesel Generator Building, Isolation

Valves Cubicles (IVC) and Reactor Containment Building; Unit 2: Re' actor

Containment Building, MEAB and Fuel Handling Building, and Balance of Plant

(B0P): support equipment areas, Main _ Cooling Reservoir, and Emergency

. ' Operations Facility.

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The NRC inspector observed a continuing effort to upgrade and maintain

the inplace protection of permanent plant equipment. These efforts include

trace and strip heating, plywood protection boxes and cages, fire retardant -

plastic dust covers, air filtration covers and caps and plugs for open

systems-. No unacceptable conditions were noted. Housekeeping is being

maintained at an acceptable level through the plant. there has been a

significant reduction of construction debris and the plant areas have been

purged of noncurrent construction material which has been segregated, QC

inspected and returned to warehouse or surplus yard as appropriate. The NRC

inspector observed this effort, including the reinspection. All activities

were conducted within the approved procedural requirements.

No violations or deviations were identified.

3. Licensee Action on Previously Identified Items

(Closed) Unresolved Item 498/499-8508-01 Permanent Plant Maintenance

This' item concerns the Permanent Pl' ant Maintenance (PPM) program and its

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implementation with regards to greasing. The NRC inspector has reviewed

verification data of the PPM program, grear.ing phase, and has determined

that the licensee permanent plant equipment maintenance program is

! unacceptabl e. This Unresolved Item 498/499-8508-01 has been determined to

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be an apparent violation 498-8515-01/499-8514-01. The unresolved item is

~c onsidered closed. See paragraph 4 of this inspection report for details

of this apparent violation.

(0 pen) Violation (8507-01)

This item refers to a prior NRC. inspection of HL&P's Mechanical and Test

i Equipment (M&TE) Control Program. The HP,C inspector noted cases of

procedural noncompliance with Plant General Procedure PGP-3-ZM-1,

Administrative Site Procedure ASP-23 and Quality Control Procedure

QCP-12.1. The noncompliances dealt with: M&TE not in recall system, M&TE

overdue for recalibration, Tool Data & Issue / Record Cards not being

l annotated with required information and incorrect tagging of equipment.

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The NRC inspector's follow-up of the corrective steps taken by the

licensee indicates that the Tool Data Issue / Record Cards are not being

annotated with the required data specified in procedure PGP-3ZM-01 and

QCP 12.1. When M&TE equipment is used on "non-safety related

activities," an entry is required by the supervisor of the user to be

entered on the Tool Data Issue / Record Card. Fifteen (15) Record Cards

were observed to be missing this entry. Additionally, PGP-3-ZM-1,

QCP-12.1, and ASP-23 require M&TE to be immediately returned to the o

calibration laboratory when the calibration sticker indicates that the

calibration period has expired. The inspectnr noted that 30 pieces of

equipment had exceeded the calibration period .(from 2-18 days) and have

past due notices issued. This equipment is still in the field.

The above violation will remain open.

(Closed) Violation (8507-02)

The M&TE laboratory employs Plant General Procedures PGP3-ZM-1,

Section 3.13 to control the recall of M&TE. The laboratory also utilizes

a " check-in/out" log which annotates issue / receipt of M&TE. This log

indicates two pieces of test equipment, a Simpson multimeter and torque

wrench, have the same identification number (ST-CC-3002). Additionally,

the lab uses a M&TE past due tracking log. Neither of these logs are

addressed in PGP3-ZM-1 nor are there approved procedures which explain the

purpose, responsibilities or actions to be taken in the use of these

. logs as required per 10 CFR 50 Appendix B Criteria V and QAPD Section 5.

A review of the corrective steps taken indicate that the " check

in/out" log has been discontinued and procedure PGP3-ZM-01 has been

revised to incorporate the use of the recall 109 Discussions with

the M&TE laboratory personnel revealed they. have clear understanding

of the use of the recall log.

The above violation is closed.

4. ' Permanent Plant Maintenance (PPM) (4-84-A-194)

In December 1984, an allegation was received by the NRC resident

inspector regarding the quality of the PPM program. Generally, the

allegers' concerns were; inadequate direction on Maintenance Action

Card (MAC) actions, potential for commingling of grease and inadequate

management involvement with the application of PPM programs and problem

resolution. The person involved agreed to a meeting with the licensee and

the NRC inspector to further discuss the issues. The licensee took the

action to investigate the concerns and issued a Significant Deviation

Report (SDR) to start the investigation. In February 1985 the SDR

corrective actions were rejected by the licensee QA Organization and the

SDR was reissued as Revision 1.

In June the NRC inspector issued an unresolved item (498/499-

8508-01) regarding the PPM and MAC activities when problems were found on

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nonsafety air compressors. This action was initiated because these PPM

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and MAL records systems are also used to control safety-related activities.

This action, along with the SDR, prompted a major grease verification

program which included trairing of all craftsman and supervisors involved

with the PPM program, in the p:oper methods of greasing and a 100% check

of all safety and nonsafety permenent plant equipment. This grease

verification program included a 100% QC witness of the "as found" condition

of safety-related equipment. The report, " Grease Verification Program

Follow-Up Report," dated August 2,1905, gave the following maintenance

discrepancy (MD) results:

a. Mixing of grease types (commingling) 148 MDs

b. Damaged equipment (not grease related) 18 MDs

c. Over-greasing (verifiable) 3 MDs

d. Component TPHS tags missing 8 MDs

e. Sealed bearings being greased (verifiable) 5 MDs

f. Items verified, but not in MAC program 18 MDs

g. Motors missing unable to verify 4 MDs

h. Turned over to HL&P S/U, but still in MAC 5 MDs

i. Requirement is grease, but has oil 7 MDs

The above MDs include both safety and nonsafety discrepancies.

There were 99 discrepancies identified on 234 pieces of safety-related

equipment. It should be noted that, while the numbers of items c and e

are relatively low, they may be misleading because the MDs noted were

those obvious from a visual examination. The licensee has indicated that

equipment will be disassembled on a case by case basis prior to systen

turnover to startup.

The South -Texas Quality Assurance Plan, in Section 13.3, requires

". . . protection and control necessary to assured that the requisite

quality of those important parts . . . are preserved . . ." WPP/QCI 28.0,

Revision 11, " Maintenance of Materials and Equipment," Section 5.2,

requires maintenances instructions and requirements to be adhered to

unless otherwise specified by Specification 5A300GS100 or the supplier.

Construction Maintenance Instruction (CMI)-1, " Care and Maintenance of

Permanent Plant Items," establishes the PPM and MAC systems to insure

equipment is protected and proper maintenance is performed.

As noted above, safety-related equipment was not properly maintained in

that 99 out of 234 pieces of safety-related equipment (approximately 42%)

had maintenance discrepancies identified during the grease verification

program.

- This is considered an apparent violation (498-8515-01/499-8514-01.)

5. Startup and Maintenance Activities

The NRC inspector observed the prerequi. site testing of Class 1E and

non-1E electrical breakers and transformers in the Unit 1 Turbine

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Generator Building and the Mechanical and Electrical Auxiliary Building.

The testing was being ducted using approved test procedures, with

calibrated test equipm The startup test engineers and maintenance

craftsman appeared to u stand the test requirements and acceptance

criteria. Selected data sheets were reviewed and found to be generally

complete and acceptable. Equipment was properly tagged out per plant

operational procedure OPGP03-Z0-0001, " Equipment Clearance."

The hydrolasing of various primary support system was reviewed and

witnessed by the NRC inspector. Hydrolasing is a process of high

pressure water cleaning inside the pipes being performed before the

system flushes. All activities observed were being performed in a

controlled, effective manner by the responsible startup engineer.

No violations or deviations were identified.

6. Exit Interview

An exit interview was conducted on October 3, 1985, with those

personnel denoted in paragraph one of this report. During the exit

interview, the NRC inspectors summarized the scope and findings of

this inspection.