IR 05000498/1987077

Insp Repts 50-498/87-77 & 50-499/87-77 on 871214-15. Deviations Noted.Major Areas Inspected:Followup of Actions Taken to Correct Issues Identified in Operational Readiness Insp Documented in Insp Rept 50-498/87-45

ML20148R813
Person / Time
Site:	South Texas
Issue date:	01/23/1988
From:	Gagliardo J, Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148R710	List: IR 05000498/1987077
References
50-498-87-77, 50-499-87-77, NUDOCS 8802020281
Download: ML20148R813 (12)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-77 Operating License: NPF-71 50-499/87-77 Construction Permit: CPPR-12 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

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Inspection Conducted: December 14-15, 1987

. I Inspector: , d A E. Q4gliardo, Chief, Operational Program Section I/*/

Date Divisich of Rea tor Sa ty Approve

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/)2) [h l 5 I .

.filh n, Director, Division of Reacter Safety Date "

Inspection Summary Inspection Conducted December 14-15, 1987 (Report 50-498/87-77)

Areas Inspected: Special, unannounced inspection to followup on tha actions taken to correct the issues identified in the operational readiness inspection documented in NRC Inspection Report 50-498/87-4 Results: Within the area inspected, no violations were identified, but four deviations (failure to meet stated commitments, paragraph 2) were identifie Inspection Conducted December 14-15, 1987 (Report 50-499/87-77)

Areas Inspected: No inspection of Unit 2 was conducte Resuits: Not applicable, g20202sl 800127 g ADOCK 05000490 PDR

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4 DETAILS

- Persons Contacted Licensee Personnel R. Alfaro, Shift Administrative Aid P. Appleby, Manager, Nuclear Training C. Buede, Reactor Operator M. Carnley T&C Maintenance Division Manager L. Clark, Supervisory Project Engineer J. Constantin, Supervisor, Simulator Training M. Duke, Lead Electrical Engineer S. Eldridge, Unit 2 Operations Manager R. Ericson, Senior QA Specialist E. Fischer, Senior Engineering Specialist J. Gallagher, SAFETEAM Investigator Coordinator

• J. Geiger, General Manager, Nuclear Assurance J. Godsey, Reactor Performance Engineer

• J. Goldberg, Group Vice President, Nuclear J. Green. Manager Inspection & Surveillance R. Hamilton, Shift Supervisor

• S. Head, Supervising Engineer R. Hernandez, Senior QA Engineer t

H. Johnson, Unit 1 Operations Manager

• W. Kinsey, Plant Manager J. Kubenka, Training Manager Staff. Training Division

J. Loesch, Operations Manager

. M. Ludwig, Maintenance Department Manager N. Midkiff, Director, ISEG T. Morris, Maintenance Training Coordinator W. Mutz, Integrated Planning & Scheduling Manager E. Nichols, Electrical Maintenance Division Manager C. Ottino, Lead Investigator

• S. Rosen, General Manager, Operations Support M. Smith, Unit 1 Outage Manager K. Trippet, Lead Engineer

" 8. Turjillo, Analysis Project QA Supervisor

• Vaughn, Vice President, Nuclear Plant Operations J. Walker, Operations Support Manager G. Weldon, Training Manager, Operations Training Division R. Whitley, Senior QA Specialist

• J. Westermeier, General Manager, South Texas Project l F. Wiens, Support Technical Supervisor M. Wisenburg, Manager, Engineering & Licensing

• Denotes those individuals attending the exit meetin ,

The NRC inspector also contacted other licensee and contractor personnel during the course of the inspectio . Followup on Items Previously identified in the Operational Reediness Inspection This inspection involved the followup of the findings from the operational readiness inspection performed in July 1987. The findings which are documented in NRC Inspection Report 50-498;499/87-45 were also discussed in the exit interview on July 2, 198 The licensee responded to the findings discussed at the exit interview in a letter dated July 15, 1987 (ST-HL-AE-2298). This inspection reviewed the licensees corrective action and commitments as stated in the July 15 letter. The status of each of the stated observations is indicated belo (Closed) Observation No. 1: Only NP0D personnel had been provided the opportunity to view the video tapes discussing the transition to the operating phase and the experience of other recently licensed plant In response to this concern, the licensee committed to provide the opportunity for personnel in ISEG, QA, Licensing, and Engineering to view the tapes. The NRC inspector reviewed the Training Department records of those personnel who had viewed the three lessons learned video tapes which had been developed. The records showed that a substantial number of people in Engineering, Maintenance, QA, and ISEG had viewed the tape This issue is close .

(Closed) Observation No. 2: Additional personnel such as those on NRSB, PORC, QA, and ISEG who will be involved in the review of 10 CFR 50.59 safety evaluations need to be trained in their review responsibilitie The NRC inspector found that a training session (IP-3.20 Q) had been developed and presented to most of those individuals involved in 10 CFR 50.59 safety evaluation preparation and review. The training records reviewed indicated that a substantial number of personnel in the Engineering, QA, and ISEG organizations had satisfactorily completed the training. All of the current members of NSRB had also received the training. The NRC inspector was concerned that 2 of the 5 PORC members had not completed the training. Of the 12 alternate PORC members, 5 had also failed to complete this training. This item is considered closed but management needs to assure that all PORC members and their alternates have received this important trainin (0 pen) Observation No. 3: A weakness was identified regarding the adequacy of the training given to those individuals who prepare or review licensee event reports (LERs). In particular, emphasis was needed in determining the gen?ric implications and the root cause of event In the licensee's response to this observation a comitment was made to train personnel who are expected to be involved in preparing and reviewing

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l LER The commitment stated that the training would be completed b t initial criticality and would specifically address. generic implications

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and root causs evaluation The NRC inspector was provided a copy of a memorandum dated August'10, 1987,-(M. McBurnett to M. Wisenburg) which included attendance sheets and a' sample handout for a training course entitled "Station Problem Reporting (IP 1.45Q). The procedure (IP 1.45Q), which was part of the handout,-

requires that !'the assigned Responsible Department / Divisions doing the investigation will determine the root cause(s) and generic implication (s)." There was no indication, however, that the training

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included guidance as to how the root cause and generic implications would be determined. The NRC inspector reviewed the attendance sheets and found that apparently some of the PORC, NRSB, and ISEG members had not participated in this trainin This item will remain open until the above issues have been resolve (0 pen) Observation No. 4: The licensee was requested to consider the need for an independent overview of the activities of the Work Control Center (WCC) by QA and/or ISE In response to this observation, the licensee stated that QA had recently performed a review of WCC activities and that ISEG would be conducting an observation of WCC activities in the near futur The NRC inspector found

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that QA had assessed the Master Completion List (MCL) and Daily Work Activity Schedule (DWAS) process and documented these assessments in reports dated June 24 and July 23, 1987. The ISEG observation was conducted on September 1-3, 1987, and was documented in a report dated September 10, 198 The licensee also committed that "WCC activities are currently included in maintenance audit plans." The NRC inspecter found, however, that the

current maintenance audit plan "Audit D3 - Maintenance Activities," dated

July 13, 1987, did not contain provisions for a review of WCC activities.

The Operations QA Manager also told the NRC inspector that he had never intended to audit WCC activities. The licensee's failure to include a review of WCC activities in their maintenance audit plans is an apparent deviation from the commitment stated above (498/8777-01). This observation will remain open until the oversight issue is resolve (Closed) Observation No. 5: A program is needed to identify and protect plant equipment which may contribute to spurious plant trips or safeguards

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activation if not adequately posted or protected.

The licensee committed to form a review team to determine sensitive equipment and to recommend the appropriate physical protection, or warning

signs, to protect the equipment. The NRC inspector found that the

committed review team had been formed and had begun the planned review.

1 The review was scheduled to be completed by December 31, 1987, which would j narrowly meet the committed deadline of initial criticality. The review team had already initiated action to place warning tape on sensitive

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equipmen Protective barriers that would be considered necessary by the review team were to be installed after the review was completed. This item is considered close (Closed) Observation No. 6: Additional emphasis is needed on the testing of the unique features of the plant desig The licensee coninitted to form a team to review the unique design features of the plant and determine the adequacy of the testing program. The NRC inspector found that the special review team had been formed and had reviewed the testing of the unique design features. The team issued a report dated November 11, 1987, which identified an additional test for the in-core neutron detectors. This item is considered close (Closed) Observation No. 7: The adequacy of the staffing level of ISEG was questione In response to this observation, the licensee noted that the ISEG staffing level was in compliance with TS requirements, but they committed to reassess the resource requirements of the group. The NRC inspector found tFat ISEG management had requested another person be added to their staffing leve This item is close (Closed) Observation No. 8: Additional training was needed for the training personnel involved in the training of the operating staf In response to this observation, the licensee noted that they were currently meeting the requirements of the requalification program for those instructors who are licensed SR0s. The NRC inspector reviewed the instructor training records and found no discrepancies. The licensee had also instituted a program which would have two instructors temporarily assigned to the operations staffing for a 3-month period. The program would be repeated twice to ultimately provide six instructors with augmented training. This item is close (Closed) Observation No. 9: The licensee needs to evaluate the need for placing protective covers over the sensitive switches on the main control panel, the licensee had formed a management review team to evaluate this issu The team walked down the panels and concluded that switch covers only hinder the operator's response capabilitie It was noted that in response to a similar observation made by the Project Review Team, a number of pushbutton switches had been recessed and the springs on other switches had been strengthened to prevent inadvertant actuation. This item is considered close (Closed) Observation No. 10: Apparent friction between the operations and training staff _ _ - _

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The licensee had. implemented a program of rotating individuals between the two organizations. The NRC inspector interviewed a number of individuals from both organizations and found that all believed that the situation has significantly improved. The licensee has comitted to continue monitoring this situation. This issue is considered close (Closed) Observation No. 11: Licensed Operators had received only one week of simulator training in calendar year 198 In response to this concern, the licensee stated that the licensed operators were scheduled for an additional week of simulator training beginning the week of July 13, 1987. The NRC inspector reviewed the records of Training Cycle 3 (703) and found that the training had begun on July 13 as committed. The NRC inspector also found that Cycle 4 was scheduled to begin in January 1988. This item is considered close (Closed) Observation No. 12: Simulator training should include the simulation of actual operating events in the industr In response to this observation, the licensee noted that the simulator training given to licensed operators had included specific events such as (1)theGinn.'steamgeneratortuberupture;(2)theSalemATWSevent; (3) the TMI stuck open PORV; and (4)-the STP water hammer event in the RHR system. The NRC inspector verified that the' committed training had been performed. Tha licensee has also committed to continue developing action plans for training operators. This item is considered close (Closed) Observation No. 13: Drawing controls for the control room and auxiliary operators needs to be improve The licensee had assigned shift administrative aides to each shift to support control room operators administratively. The drawing files in the control room had been removed and replaced with stick files. The NRC inspector interviewed an administrative aide and reviewed her shift check list. The control of drawings in the control room and for the plant operators had been significantly improved. This item is considered close (0 pen) Observation No. 14: Consideration should be given to placing an LC0 status board in the control roo In response to this observation, the licensee noted that they currently had procedures which provided for LCOs to be entered on a loa sheet. The licensee also noted that the Out of Service Log would be reviewed as part of shift turnover. Since the LC0 log sheet may not be visible to all operators in the control room, the licensee committed to have entries made in the Unit Supervisor and control room logs upon entry into an LCO and when exiting from an LCO. The NRC inspector found that the entry into and the exit from an LCO was not being entered into the control room log nor were such entries required by the existing control room procedure (OPSP03-7Q-0001 Revision 1, dated July 31,1987). The failure to require

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that entries be made in the control room log of entry into an LC0 and exit from an LC0 is a deviation (498/8777-02) from the above stated commitmen This item will remain open until the above issue is resolve (0 pen) Observation No. 15: The licensee should reevaluate the practice of not logging equipment clearances by syste In response to this observation, the licensee noted that although equipment clearances are not cataloged by system, each clearance has a designator for the system. They also stated that since a high percentage of clearances ultimately affect components of more than one system it is difficult to isolate clearances by system. The NRC inspector found that the clearance log did indicate the system that was most impacted by the clearance, but it did not indicate the other systems which were affected by the clearanc With this system, it would be difficult for an individual to determine all of the clearances which impact on a given system. This practice could result in undesirable events because of the difficulty to accurately determine system status. The NRC inspector asked the licensee to reevaluate their practic The licensee agreed to look at how other plants control clearances. This issue will remain open until the licensee has raevaluated their system for clearance contro (Closed) Observation No. 16: The licensee should reassess the frequency of plant walkdowns by the operating staf The NRC inspector found that the licensee had placed increased emphasis in this area. Two unit supervisors were assigned per shift, one of whom did plant rounds (tours) while the other remained in the control room. The reactor plant operators performed the required surveillances and the plant operators had specifically prescribed rounds to perform in the plan This item is considered close (Closed) Observation No. 17: Need for precautions to prevent cable damage due to personnel entry into the cable bridge storage vaul The licensee committed to administratively control entry into the cable bridge storage vault. The NRC inspector found that warning signs had been posted in the vault. Licensee representatives said that tape baricades were also put in place to restrict entry into the vault when the head was removed. This item is considered close (Closed) Observation No. 18: Hard to reach places needed additional cleanin The NRC inspector toured the plant and found that the cleanliness of the plant, including the hard to reach areas, had been considerably improve This item is close (Closed) Observation No. 19: Additional training is needed on feedwater control at low power level _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

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In response to this observation', the licensee noted that the licensed operators had been trained on the feedwater control system in the classroom and on the simulator. They also noted, however, that the simulator had only recently been modified to model the startup feed pum The NRC inspector found that a Westinghouse engineer had given additional training on the feedwater controls and the operators had also received simulator training on the startup feed pump controls during Cycle 3 retraining. This item'is considered close (0 pen) Observation No. 20: Investigating anonym us tips or allegations of drug usag The licensee's initial response to this observation (letter dated July 15, 1987) was not adequate and at the request of the inspector, their commitments were modified in a letter dated August 18, 198 The NRC inspector reviewed the revised fitness-for-duty policy and the revised SAFETEAM procedures to verify that all of the committed changes had been made. All of the comitted policy and procedure changes had been made as comitted. In the licensee's August 18 response, a statement was made that "In addition NSD will contact local law enforcement officials concerning the subject of the anonymous tip." The NRC inspector interviewed an NSD (Security) representative and found that NSD did not contact local law enforcement officials unless the allegations had been confirmed or a substantial amount of information was provided by the anonymous alleger. This is a deviation (498/8777-03) from the commitment made in the August 18, 1987, letter. This item will remain open until the issue is resolve (Closed) Observation No. 21: The licensee needs a program for processing additional concerns that are brought to the attention of a SAFETEAM investigator during investigation The licensee had revised Procedure ST-03 on November 1, 1987, to incorporate means for handling additional concerns. SAFETEAM investigators had been trained on the new procedures. The investigators were also interviewed to determine if additional concerns had been brought to them in the past and had not been fully investigated. Two concerns were identified by this process and were subsequently investigated. The I concerns were not substantiated. This item is considered closed.

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l (Closed) Observation No. 22: The classification of concerns was not being l independently verified and two concerns were classified as Class 2 but

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appeared to be Class 1.

l The General Manager, Nuclear Assurance (GMNA) and his staff reviewed 1161 i

past concerns to verify that the original classification was appropriat Of those concerns reviewed, 16 were found to be inappropriately classified and were reclassified as Class 1. These 16 concerns were investigated by SAFETEAM and appropriately dispositione The NRC inspector also noted l

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that Procedure ST-02 had been revised on November 1, 1987, to require that the GMNA review the classification of all new SAFETEAM concerns. This item is close (Closed) Observation No. 23: Root cause, generic implications, and the appropriate corrective action was not always determined, or taken, for significant concerns that had been substantiate The licensee established a special review team to evaluate the adequacy of the root cause and generic implication determinations of significant substantiated concerns. Eleven concerns were returned to SAFETEAM and reevaluated, and the appropriate corrective action was tcLen. This item is considered close (0 pen) Observation No. 24: The licensee needs to provide the means to cross-reference surveillance procedures to the TS sections which would be affected by failure of the surveillance tes In response to this observation, the licensee committed to review all surveillance procedures and revise them as necessary to ensure that all affected TS are referenced. The licensee comitted to complete this effort by the end of full-power testing. The NRC inspector reviewed the progress of this effort. The Reactor Operations Group had essentially completed their assigned reviews, but many of the other groups had not shown significant prooress in this effort. This item will remain open until significant progress has been shown in this effor (0 pen) Observation No. 25: The licensee needs to assure that positive indication of actual valve position is shown for those valves whose position is verified during surveillance testin In response to this observation, the licensee stated that the STP method for determining valve position are consistent with current industry practice, but an evaluation would be performed prior to initial criticality to determine if any valves do not have positive position indication. This review had been performed by the unit supervisor on shift as surveillance procedures were perfonted. The NRC inspector found no discrepancies in this practice, but a detailed review was not performed. The adequacy of this review should be evaluated by QA and/or ISEG. This will remain open pending further review by the licensee and the inspecto (Closed) Observation No. 26: The surveillance index did not reference all of the test procedures required to satisfy TS 4.7. The licensee revised the TS index for TS 4.7.1.5 to reference both of the

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applicable test procedures. The QA group also reviewed all other l TS-required surveillances to assure that no other discrepancies exis This item is considered closed.

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(Closed) Observation No.-27: It appeared that the NRC may be unaware of the use of bypass switches to inhibit the torque switch function on motor operated velves (MOVs).

In response to this observation, the licensee noted that their practice was-addressed in their response to IEB 85-0 The NRC inspector verified that in the licensee's response to IEB 85-03, dated June 2, 1986, t h

- function of the torque bypass switches was clearly described. This item is considered close (Ciosed) Observation No. 28: Torque' and limit switch setpoints for MOVs were not readily available for use by the craft personnel who maintain the MOV The architect engineer (Bechtel) issued an MOV data base document-(1E321ELC101-R1) on September 11, 1987, which specified torque and limit switch se'ioints for all safety-related valve This data had been incorporated as a reference into the procedures for MOV maintenance. The NRC inspector noted that the crafts personnel had not yet been trained on the use of this data but the training was planned for early in 1988. This item is considered close (Closed) Observation No. 29: Torque switch settings on-BOP valves appeared to be set at the minimum valve The licensee argued in their response to this observation that the torque switch settings for 80P valves were set according to the instructions or per requirements established during preoperational testing. The NRC inspector interviewed licensee representatives who substantiated this ,

information. This item is considered close I (Closed) Observation No. 30: Some electrical maintenance personnel did not receive on-the-job training (0JT) during the preoperational testin The licensee's interim training program for the Maintenance Department was issued on May 20, 1987. A memo was issued to the department on July 24, 1987, emphasizing the need for OJT for maintenance personnel. The licensee began a reassessment of the treining program after the inspection. This reassessment was completed on October 30, 1987, and all maintenance foremen were retrained. A related training concern had been identified in NRC Inspection Report' 50-498/87-50 which involved training of electrical maintenance personnel on MOVs. The additional training indicated by that inspection had been essentially completed. This item is considered close (Closed) Observation No. 31: Some electrical maintenance personnel were not provided the opportunity to be involved in the development or walkdown of maintenance procedure In response to this observation, the licensee noted that "scheduling and manpower constraints had prevented all technicians from being involved

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with procedural development. They noted that the normal development of the technicians through 0JT and formal classrcom training will assure adequate training for the performance of their activitie The NRC inspector verified that the licensee had developed an adequate 0JT program, but the program did not provide for supplemental training for those technicians who were not involved in procedural development. This item is closed, but the licensee should reevaluate the need for supplemental training for those technicians who were not involved in procedure developmen (Closed) Observation No. 32: The licensee needs to reevaluate the need for improved training of electricians i.. the methods of troubleshooting battery chargers and inverter The licensee had developed three courses on the theory and maintenance of solid state electronics equipment. The first two of these courses (Solid State I and Solid State II) had been presented to nine of the licensee's technicians. These courses were primarily theoretical, and did not provide detailed instructions on troubleshooting techniques for solid state equipment like the battery chargers and inverters. The third course (Solid State III) will provide training on the maint.enance and trouble-shooting techniques, but this course is not scheduled to be taught until July 198 The licensee argued that they have technicians who they believe were currently qualified or the battery chargers and inverter They also argued that they would bring in vendor representatives if necessary. This item is considered close (Closed) Observation No. 33: The inspection team questioned the licensee's intended actions in response to ISEG observations on reactor operator rounds and shift turnove In response to this observation, the licensee had two senior level managers go into the plant and accompany operators on their rounds. Upon completion of this effort, a meeting was held with the operations staff to discuss this concern. Additional on-shift training was held on this subject. This item is considered close (Closed) Observation No. 34: The inspection team questioned the licensee's intended actions in response to the ISEG assessment and subsequent concerns on manual valve reach rod In response to this observation, the licensee developed a list of the manual valves with reach rods and physically tested the operability of each valve. The NRC inspector found that all of the valves had been '

tested. Six problems were found which related to valve positio Maintenance work requests (PWRs) were issued and the six valves were repaired. The licensee has cocrnitted to perform post-maintenance tests on future valve repairs or installation. This item is close (0 pen) Observation No. 35: The inspection team was concerned that ISEG reports are not required to be addressed by the pl?nt staff, i

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In response (letter of July 15,1987) to this observation, the licensee conmitted to write a procedure which would specify actions to be taken as a result of ISEG reports. The procedure was to be completed by September 30, 1987, and as an intorim measure responses for ISEG reports will be generated by responsible managers. The responses would address pertinent issues identified in the ISEG report. The NRC inspector found :

that the licensee had developed and issued an Interdepartmental Procedure IP-1.39 dated September 28, 1987, which addressed this concer The NRC inspector found, however, that ISEG had issued a report entitled l

"ISEG Observation of the Work Control Center," dated September 10, 1987, and that no response had been made to the report. The re; ort documented several findings which were pertinent to the operation of the WCC, but none of the four managers addressed on the repor', responded. The failure of any of these managers to respond to the ISEG report constitutes a deviation (498/8777-04) from the licensee's connitment as stated abov This item will remain open until the issue is resolve ,

I (Closed) Observation No. 36: The inspection team identified 12 open SAFETEAM concerns for which sufficient information wts not available to .

determine if the concern could affect fuel loa The NRC inspector reviewed the records of the subject concerns. All of i the concerns had been closed as of August 10, 1987. This item is considered close . Exit Interview ,

The NRC inspector met with the licensee representatives (denoted in paragraph 1) on December 15, 1987. The NRC inspector summarized the scope of the inspection and the findings. The NRC inspector expressed concern regarding the licensee's commitment tracking system as evidenced by the inspection finding .