ML20153B611
| ML20153B611 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/28/1988 |
| From: | Robert Evans, Gagliardo J, Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20153B603 | List: |
| References | |
| 50-498-88-17, 50-499-88-17, NUDOCS 8805060040 | |
| Download: ML20153B611 (12) | |
See also: IR 05000498/1988017
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-498/88-17
Operating License:
50-499/88-17
Construction Permit:
CPPR-129
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Dockets:
50-498
50-499
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Licensee:
Houston Lighting & Power Company (HL&P)
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P.O. Box 1700
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Houston, Texas 77001
Facility Name:
SouthTexasProject(STP), Units 1and2
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Inspection At:
Inspection Conduct d:
March 2-3, 1988
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Inspectors:
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J. Ej. iGagliardo, Chief, Operational Programs
Dite '
Seb) ion,DivisionofReactorSafety
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R Evart, Reactor Inspector, Operational
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Safety
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Approved:
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l{oan, DirecCor, Division of Reactor
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Inspection Summary
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Inspection Conducted March 2-3, 1988 (Report 50-498/88-17)
Areas Inspected:
Special, unannounced inspection to followup on the actions
taken to correct the issues identified in the operational readiness inspect'ons
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documented in NRC Inspection Reports 50-498/87-45, 50-498/87-77, and
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50-498/88-01,
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Results:
Within the areas inspected, one violation (failure to follow
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procedure, paragraph 2) was identified.
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Inspection Conducted March 2-3, 1988 (Report 50-499/88-17)
Areas Inspected:
No inspection of Unit 2 was conducted.
Results:
Not applicable.
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DETAILS
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1.
Persons-Contacted
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HL&P
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P.'Appleby, Manager, Nuclear Training Department-
C. Ayala, Supervising Engineer, Event Reporting
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R. Balcom, Audits and Assessment Manager-
L. Casella, Supervising Project Engineer
L. Clark, Supervisory Project Engineer
J. Constantin, Supervisor, Simulator Training
A. Harrison, Supervising Project-Engineer
H. Johnson, Unit 1 Operations Manager
J. Loesch, Plant Operations Manager
J. Hertink, Lead Engineer
N. Midkiff, Director, Independent Safety Engineering Group
B. Munter, Principle Engineer
.W. Mutz, Integrated Planning & Scheduling Manager
M. Smith, Unit 1 Outage Manager
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R. Snow, Lead Training Instructor
N. Tasker,-Manager, Security Department
K. Trippel, Lead Systems Engineer
- G. Vaughn, Vice President, Nuclear Operations
J. Walker, Manager, Operations Support Group
- Denotes those present at the cxit meeting on March 3, 1988.
The NRC inspectors also contacted other licensae a.1d contractor personnel
during the course of the inspection.
2.
Followup on Items Previously Identified in the July 1987 Operational
Readiness Inspection (Inspection Report (IR) 50-498/87-45) and Subsequent.
Followup (IR 50-498/87-771
'This portion of the inspection involved the followup of the findings from
the operational readiness inspection performed in July 1987 and the
subsequent followup inspection (IR 50-498/87-/7).
The licensee responded
to the deviations documented in IR 50-498/87-77 by letter dated
February 26, 1988.
The status of each of the deviations and open items is
indicated below.
(Closed) Deviation 498/8777-01:
Failure to Audit Work Control
Center (WCC) Activities - In the licensee's response
(Letter ST-HL-AE-2532, dated February 26,1988) to this deviation
reference was made to the original response to this issue in +. heir letter
(ST-HL-AE-2467) dated December 31, 1987.
The licensee noted that quality
assurance (QA) had performed an assessment of WCC activities in June and
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July 1987.
The licensee also noted that QA audits of maintenance
activities in July 1987 and of corrective action activities in August 1987
included a review of WCC activities.
The NRC inspectors reviewed the records of the above activities. The
assessments were designed to determine the adequacy of the WCC process of
List (MCL) g open construction issues from the Master Completionto the; newly
transferrin
This effort was primarily intended to assure the traceability of the
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transfer process.
The assessments did not deal with WCC activities which
would be performed after fuel load when the MCL to DWAS transfer would be
essentially complete.
The audit of maintenance, reviewed maintenance activities, and how they
were controlled after the maintenance documents had been processed through
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the WCC.
The audit did no+. look at the specific WCC activities which
involved the planning, scheduling, and processing of the work control
documents.
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The corrective action audit did review WCC activities. The report for
this audit (Audit No. 87-18) documented a program deficiency for "failing
to develop administrative / implementing procedures for the' Work Control
Center processing of MWRs and for Outage Management control of the DWAS
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, data base." This deficiency was riocumented in DR No. 587-065.
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In response
dis DR, the licensee develog d a WCC procedure
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W) which was approved and issued on December 31, 1987.
Licensee representativas noted "that Nuclear Assurance audit process will
continue to include WCC and DWAS activities in its audits."
In an
interview with the NRC inspectors, the Manager of Independent Safety
Engineering Grcup (ISEG) will continue to observe WCC activities. This
issue is considered closed.
This effort alsa closes Observation No. 4 from IP. 50 e93/87-45.
(Closed) Deviation 498/8777-02:
Entries of Entering and Exiting from
Limiting Condition for Operation (LCO) Conditions in the Control Room Log
- In response to the original inspection observation (IR 50-498/87-45),
HL&P committed to require operator entries in the unit supervisor and
control room logs of the plant's entry into and exit from Technical
Specification (TS)LC0 conditions. This was to be done in lieu of placing
an LC0 status board in the control room.
During the followup inspection (IR 50-498/87-77), the NRC inspectors noted
that LC0 entries and exits were not being entered into the control room
(or'reactoroperator) log. These entries were not required by existing
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procedures at that time. The failure to make LCO entries into the reactor
operator log was identified as a deviation from the licensee commitments.
This resulted in a Notice of Deviation (498/8777-02).
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During this inspection (IR 50-498/88-17), the NRC inspectors reviewed
licensee commitments in their letters dated December 31, 1987, and
February 26, 1988, to revise the applicable procedure.
The NRC verified
that Procedure OPOP01-ZQ-0030 (Revision 2), "Maintenance of Plant
Operations Logbooks," added procedural requirements to record entries into
and exits from TS LCOs in the reactor operator log book.
A review of the reactor operator and unit supervisor log books was
performed to ensure compliance to the revised Procedure OPOP31-ZQ-0030.
The dates checked include February 29 through March 3, 1988.
The review
of the two log books identified several discrepancies:
a.
Several LC0 entries were found in either the reactor operator or unit
supervisor log books, but not both.
Procedure OPOP01-ZQ-0030
(Revision 2) requires entries into and exits from LCOs to be recorded
in both logs;
b.
Numerous LC0 required entries in the reactor operator log were noted
to be "late entries;" and
c.
By comparing the two log books, the NRC inspectors identified four
log entry mistakes, including wrong TS section recorded, failure to
write TS sections and mixing the words "enter" and "exit."
All of the discrepancies noted were discussed with HL&P personnel.
STP-1 TS Section d.8.1 requires written procedures to be established,
implemented and maintained covering the activities recomended in
Appendix A of Regel; tory Guide (RG) 1.33 (Revision 7.).
Appandix A,
Item 1.h, requires log entry procedures.
Procedura OPOP01-ZQ-0030 meets,
in part, the intent of item 1.h of RG 1.33, Appendix A.
Proce: dure OPOP01-ZQ-0030 (Revision 2), Section 6.2 and 6.3, require
entries into the reactor operator and unit supervisor log bocks to include
"entry into or exit from Technical Specification Action Statements."
The failure to record TS LC0 entries and exits in both reactor operator
and unit sepervisor log books is an apparent violation (498/8817-01) of
the TS 6.8.1 requirement delineated above.
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It was noted that Procedure 0P0P01-ZQ-0030 was in the process of being
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updated to Revision 3, with an effective date of March 5, 1988.
The
revised procedure would require only one log, a control room log, and
would implement an operability tracking log, to track LCOs.
The NRC
inspectors noted that the implementation of this procedure would be a
deviation from their commitment to address Observation No.14 as stated in
their letter ST-HL-AE-2298, dated July 15, 1987.
This deviation and Observation No.14 are considered closed; however, the
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above apparent violation will be tracked to closure.
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(Closed) Deviation 498/8777-04:
Failure to Respond to ISEG Observation
_ Report _ - In the licensee's letter (ST-HL-AE-2467) dated December 31, 1987,
they stated that "ISEG determined that a response to this observation was
not required. A reevaluation has determined that a formal response to the
observation should be provided."
The NRC inspectors could find no evidence of a written policy which would
have countermanded the comitment made in the licensee's letter
(ST-HL-AE-2298) dated July 15, 1987, to have responses generated for ISEG
reports prior to the issuance of Interdepartmental Procedure IP-1.39.
The
NRC inspectors did note that the Director, ISEG had questioned, by undated
memorandum to his supervisor, the practice of not requiring a formal
response to ISEG observations .
The NRC inspectors reviewed the response (dated January 20, 1988) to the
September 10, 1987, ISEG report.
The response appeared to address the
issue that had been raised by the report.
As noted in the discussion for
Deviation 498/8777-01, a procedure had been issued to control WCC
activities.
This issue is considered closed. Observation No. 35 from NRC
IR 50-498/87-45 is also closed.
(Closed) Deviation 498/8777-03:
Investigation of Anonymous Tipv. Relatin
to Drug Use - In the licensee's letter of February 26, 1988, it wae.~iIo e
that they had reevaluated their original commitment on this issue. They
had concluded that the local law enforcement officials would be notified
only if enough specific information was provided to lend credibility to
the referral.
The NRC inspectors discussed the licensee's position with tt.e NRC security
specialist that had originally raised the concern.
The security
specialist stated that the licensee's position was acceptable provided
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that a member of SAFETEAM or security management makes the final decision
as to whether or not sufficient information has been provided to make the
referral.
Licensee representatives assured the NRC inspectors that such
decisions would be made at the management level.
The NRC inspectors reviewed the latest revision (Revision A) to the "STP
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Orug and Alcohol Screening Behavioral Observation Action Guidelines for
Fitness for Duty Program," which was approved on January 7, 1988. The
procedure had been revised as committed by the licensee.
This deviation is considered closed.
This also closes Observation No. 20
from NRC IR 50-498/87-45.
(Closed) Observation No. 3: Adtplacy of Training for Those Who Prepare or
Review Licensee Event Reports - De NRC inspectors reviewed the records of
the Root Cause Analysis Training (Course No. 101) provided by the
Director, ISEG to the members of the Plant Operations Review
Comittee (PORC), Nuclear Safety Review Board (NSRB), and ISEG.
The
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training was also provided to operations, licensing, and engineering
personnel who were involved in the preparation of Licensee Event
Reports (LERs).
This item is considered closed.
(Closed) Observation No. 4:
Audit of WCC Activities - This item was
reviewed and closed with the closure of Deviation 498/8777-01.
(Closed) Observation No. 14:
LC0 Status Board in the Control Room - This
item was reviewed and closed with the closure of Deviation 498/8777-02.
(0 pen) Observation No. 15:
The licensee should reevaluate the practice of
not logging equipment clearances by system.
The NRC inspectors reviewed STP-1 Procedure OPGP03-Z0-0001 (Revision 6),
"Clearance Procedure," and the equipment clearance log, to determine if
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there was still a concern with clearances not being cataloged by system.
In the first followup inspection (IR 50-498/87-77), the NRC asked the
licensee to reevaluate their system for clearance control.
During this inspection, the NRC inspectors reviewed clearance log entries.
Two clearances (1-88-555 and 592) were observed to have more equipment
tagged out than was listed in the associated system designator blocks.
In
both cases, equipment was identified on the clearance orders with system
desinnators different than that listed on the clearance log.
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Procedure OPGP03-Z0-0001, cnly the predominate or primary systems impacted
have to be identified by system code on the clearsnce cruer or Ing
(procedure steps 5.2.1.d and g).
The NRC inspectors indicated that all
systems should be identified by systam code on the clearance orders and
log entries.
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Durir.g the exit interview, the licensee made a commitment to change the
wording of the clearance procedure to ensure all system designators of
systems affected are listea in the clearance log
Ocservation No.15.wi' 1
remain open until the Procedure CPGP03-Z0-0001 (Revision 6) is ravised.
The licensee representatives said that the procedure would 'oc revised
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prior to STP-1 exceeding 5 percent power.
The NRC inspectors noted that
this item would remain open pending the NRC inspectors' verification of
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the procedure change, but it would not impact on the full power licensing
decision.
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(Closed) Observation No. 20:
Investigating Anonymous Tips or Allegations
of Drug Usage - This item was reviewed and closed with the closure of
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Deviation 498/8777-03.
(0 pen) Observation No. 24:
The licensee needs to provide the means to
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cross-reference surveillance procedures to the TS sections which would be
affected by failure of the surveillance test.
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In response to the original observation (IR 50-498/87-45), the licensee
committed to review all surveillance procedures and revise them as
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necessary to ensure that all affected TS were referenced.
The licensee
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committed to complete this effort by the end of full power testing.
During the followup inspection (IR 50-498/87-77), the NRC inspectors
reviewed the progress of this effort.
At that time, the surveillance
procedure review was incomplete by the licensee.
During this inspection, the licensee provided the NRC inspectors with
information about a computerized TS tracking system.
The STP TS
Management System Users Guide was reviewed by the NRC inspectors.
The
system was designed to provide assistance to the STP staff in assessing
the state of the plant with respect to TS.
The system accepts information
about the status of various components and parameters around the plant,
and decides whether or not the plant is still in compliance with its TS.
The system also provides an on-line copy of the plant TS.
The NRC inspectors found that the TS Management System was an enhancement
to the TS program.
However, the system was found not to be in use, due to
problems with the computer software.
The licensee committed to provide
the NRC with a date when the TS Management System will be operable and in
use by the plant staff.
The commitment date for operation will be
required prior to STP-1 exceeding 5 percent power.
This item will remain
open pending the licensee's resolution of the software problems or their
implementation of some other system.
The closure of this issue will not
impact on the full oower license decision.
(Closed) Obse: ation No. 2.5:
Positive Indication of Actual Valve Position
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- The NRC inspectors reviewed the !icensee s effarts to verify that all
valves subjected to surveillance testing had positive position indication.
All of the valves nad been so verified ar.d the b,o discrepancies found had
been corrected.
This item is considered closed.
(Closed) Observation No. 35:
ISEG Reports Not Being Addressed by the
Plant Sti.ff - This item was reviewed and closed with the closure of
Deviation 498/8777-04.
(Closed) Open Item 498/8745-01:
Differences Between the Simulator Design
and the Control Room - The NRC inspectors found that the simulator had
been configured to the control room design as of December 1986 with some
additional hardware changes.
The licensee had currently frozen the design
on November 15, 1987, for the next modification which is scheduled to be
completed on December 1988.
This update effort is consistent with the
guidance of RG 1.149.
This item is considered closed.
(Closed) Open Item 498/8745-02:
Operations personnel stated that the
simulator was not used for training operators regarding experiences at
recently licensed plants.
The NRC inspectors found that the simulator training program for licensed
operations did specifically address the following events:
Steam Generator Tube Rupture of Ginna,
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ATWS Event at Salem,
Pressurizer Struck Open Power Operated Relief Valve (PORV) at Three
MileIsland(TMI),and
RHR Water Hammer Event at STP.
The program also includes a segment entitled "Lessons Learned."
Each requalification cycle has scenarios scheduled which are designed to
increase the operator's awareness of events and to make the operator
proficient at dealing with those types of events.
This item is considered closed.
(Closed) Open Item 498/8745-03:
Training of Electrical and Mechanical
Maintenance Personnel to Minimize Inadvertent Scram or Engineered Safety
Features (ESF) Actuation - Refer to findings discussed for Open
Item 498/8745-05 below.
(Closed) Open Item 498/8745-04: Training of Maintenance Personnel to
Provide Feedback for Lessons Learned from Other Plants - Refer to findings
discussed for Open Item 498/87a5-05 below.
(Closed) Open Item 498/8745-05:
Training of Maintenance Personnel to
Reduce Violations - The licensee had expendedlansiderable effort to'
modify the training for maintenance personnel to satisfy the concerns that
were the basis for the above open items. The licensee had trained
approximately 50 percent of the maintenance personnel under the new lesson
plans. The NRC inspectors noted, however, that the experienced craftsmen
who had previously been through the training had not received the new
training.. The NRC inspectors asked the licensee representatives what
mechanism would be implemented to assure that all craftsmen receive the
newly revised training. The licensee representatives assured the NRC
inspectors that this would be done.
These items are considered closed.
Maintenance training in this area will be reviewed again during subsequent
reviews of the licensee's training program.
3.
Followup on the Significant Concerns in the January 1988 Operational
Readiness Inspection
This portion of the inspection involves the followup of the five
significant concerns documented in Appendix A of IR 50-498/88-01. The
licensee had not yet responded to these concerns at the time of the
inspection. Licensee representatives discussed the action that had been
taken for each of the items. The licensee's response was subsequently
issued on April 15,1988(ST-HL-AE-2539).
(0 pen) Significant Concern from paragraph 2.1.1 of IR 50-498/88-01:
Remote Shutdown - In the licensee's response of April 15, 1988, they
comitted to provide additional training for each of the Unit 1 operating
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crews used the revised P.rocedure IP0P04-Z0-001, "Control Room Evacuation."
The procedure was revised in February 1988, and the NRC inspectors
verified that the committed training had been completed.
The licensee had
also conducted drills with each operating crew to demonstrate their
ability to implement the revised procedure.
The NRC inspectors verified
that the committed drill scenario had been performed by the operating
crews.
The licensee had stated, in their response, that the senior
resident inspector (SRI) at STP had witnessed one of the drills.
The NRC
inspectors confirmed that the SRI had witnessed one of the drills and had
found it to be satisfactory.
The NRC inspectors noted that several minor
discrepancies had been identified in the drill records.
The discrepancies
primarily involved communications difficulties during the drill such as
unable to communicate with the radio handsets because of high noise levels
and phone lines which were too short.
The licensee had taken no action at
the time of the inspection to correct the identified discrepancies.
The
NRC inspectors also noted that the revised Procedure.1 POP 04-Z0-001 did not
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address the need to estaolish and maintain communications with the
Technical Support Center (TSC) or the. Emergency Operating Facility (E0F).
In all likelihood, the TSC would be unavailable with the drill scenario of
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a fire in the control room.
Under the conditions exercised, it would be
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vital that communication be established between the Auxiliary Shutdown
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Panel and TSC/ EOF.
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Since the licensee had corrected tiie original-issue, this item will not
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impact on the full power license decision.
This issue will remain open;
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however, pending the licensee's correction of the drill and procedure
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discrepancies discussed above.
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(Closed) Significant Concern from paragraph 2.1.2 of IR 50-498/88-01:
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Plant Status - In the licensee's response of April 15, 1988, they
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committed to conduct a review of General Plant Operating Procedures and
revise those necessary to raduce, better control, and document out of
sequence steps.
The licensee had revised Procedure OPGP03-ZA-002, "Plant
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Procedures," to require an independent review of new procedures including
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the use of an attributes checklist.
The NRC inspectors verified that the
licensee had begun the review of Plant Operating Procedures using the new
checklist.
The licensee had also committed to conduct additional training
for operating crews on determining plant status and the plant needs for
changing modes.
The NRC inspectors reviewed the training records for the
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Unit 1 operators and found that this training had been given to all
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operators for mode changes up to and including Mode 2.
The training for
going into Mode 1 was scheduled to be completed prior to the licensee's
exceeding 5 percent power.
This item is considered closed.
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(Closed) Significant Concern from paragraph 2.1.3 of IR 50-498/88-01:
Technical Specification Implementation - In the licensee's response
(ST-HL-AE-2541), dated March 1,1988, they committed to correct
Procedure OPSP10-II-0003, to perform a review of surveillance procedures,
and to revise Procedures OPGP03-ZA-0002 and IP-3.20Q to correct the NRC
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inspectors' concerns.
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The NRC inspectors found that Procedures OPSP10-II-0003, OPGP03-ZA-0002,
and IP-3.20Q had been revised as committed.
They had also completed the
committed review of surveillance procedures.
The licensee noted in their
response that the Procedure 1 PSP 10-RC-0001 identified as having an
acceptance criteria which references a figure no longer in the TS, was the
incorrect procedure.
They indicated that the current procedure for
measuring Reactor Coolant System (RCS) flow was 1 PEP 04-ZG-0007.
The NRC
inspectors reviewed this procedure and verified that it was the
appropriate procedure for measuring RCS flow, it had been revised on
January 20, 1988, and it did contain the appropriate acceptance criteria
from TS 3.2.5.
The NRC inspectors found, however, that Section 6.0 of
Procedure 1 PSP 10-RC-0001 still referenced Figure 3.2-3 of TS 3/4.2.3 as
the acceptance criteria for RCS flow determination.
As noted in
IR 50-498/88-01, Figure 3.2-3 was no longer in the TS.
It is noted that
the revision to this procedure, which would eliminate the reference to
Figure 3.2-3, was in final review and nearing issuance.
The NRC
inspectors were concerned that this corrective action had not been
implemented on a more timely basis.
This item is considered closed.
(Closed) Significant Concern from paragraph 2.1.4 of IR 50-498/88-01:
Station Problem Reports - The NRC had found, in IR 50-498/88-01, that the
resolution of 68 of the 204 outstar. ding station problem reports (SPRs)
were overdue by an average length of time of 40 days.
In response to this
issue, the lictnsee committed to:
(1) review the open SPRs to assure that
plant safety was not impacted, (2) revise Procedure 1.45Q to increase
management's involvement for prioritizing and resolving outstanding SPRs,
and (3) to assign additional engineers to the organization tasked with
resolving the open SPRs.
The NRC inspectors found that all of the
previously overdue SPRs had been resolved.
There was only one SPR that
was overdue and it was overdue by cnly 1 day.
This issue is cont,ider?d
closed.
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(Closed) Significant Concern from paragraph 2.1.5 of IR 50-498/88-01:
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Agastat Relay - In the licensee's response to this issue, they indicated
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that the Non-class 1E agastat relays which perform safety-related function
had been replaced.
The NRC inspectors reviewed the licensee's efforts in
this area.
Of the 39 agastat relays installed in the plant, 7 of them
perform safety-related functions and had been replaced by suitably
qualified relays.
The remaining relays, which perform nonsafety-related
functions, are scheduled to be replaced with qualified relays by the end
of 1988.
This item is considered closed.
4.
Isolation Valves for Air System to the Personnel Air Lock Seal
On February 11, 1988, HL&P engineers determined that four solenoid valves
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in the air supply lines to the containment personnel air lock seals should
have been identified as containment isolation valves.
The licensee
informed the NRC staff of this determination by telephone on February 12,
1988, followed by a letter dated February 18, 1988.
The licensee
corrective actions, as committed to the NRC, included:
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a.
Initiation of a design change to the affected circuitry,
b.
Revising procedures (until design changes were completed) to ensure
the valves remain closed when the air lock was not in use,
c.
Provide instructions on how to control the valves when using the air
lock, and
d.
Limit the use of the air lock by using administrative controls.
On March 3,1988, the NRC inspectors reviewed the modifications and
commitments made by HL&P.' The NRC inspectors attempted to determine if
the licensee commitments had been implemented.
Procedure 1T0P02-XC-0001
(Revision 0), "Personnel Airlock Operation," was reviewed by the NRC
inspectors. The procedure provides temporary instructions on the control
of the four solenoid valves.
The procedure describes how to use the
airlock while ensuring containment isolation capability is maintained.
The procedure meets the intent of the interim commitments made by the
licensee, until the modifications have been installed and tested.
The modifications to the circuitry were to include installation of a
control switch in the control room that controls all four valves,
individual valve status lights. Emergency Response Facility (ERF)
computer inputs, Containment Isolation Signal-Phase A auto close
circuitry, and installation of local test valves.
A field walkdown of the modifications made did not identify atiy additional
NRC concerns.
No violations or deviations were identified in this area;
,
however, the modifications are currently incomplete.
Therefore, this area
is considered an open item (498/8817-02) which requires further NRC
review.
5.
Exit Meeting
An exit meeting was held on March 3,1988, with the individuals identified
in paragraph 1 of this report. The NRC inspectors briefed the attendees
on the scope of the inspection and the findings as documented in this
report.
The NRC inspectors noted that those items from the operational
readiness inspections, which had not yet been closed, will not impact on
the Region IV recommendation regarding the issuance of the full power
license.