ML20206H636

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Insp Repts 50-498/99-06 & 50-499/99-06 on 990221-0403. Non-cited Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support
ML20206H636
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/05/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206H624 List:
References
50-498-99-06, 50-498-99-6, 50-499-99-06, 50-499-99-6, NUDOCS 9905110266
Download: ML20206H636 (21)


See also: IR 05000498/1999006

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ENCLOSURE I

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket Nos.: 50-498 I

50-499

License Nos.: NPF-76 >

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NPF-80 -

' Report No.: 50-498/99-06

50-499/99-06

Licensee: STP Nuclear Operating Company

Facility: South Texas Project Electric Generating Station, Units 1 and 2

Location: FM 521 - 8 miles west of Wadsworth

Wadsworth, Texas 77483

Dates: February 21 through April 3,1999

Inspectors:. Neil F. O'Keefe, Senior Resident 4

Wayne C. Sifre, Resident inspector

Gilbert L.Guerra, Resident inspector

Don B. Allen, Project Engineer

Approved By: ' Joseph I. Tapia, Chief, Project Branch A

ATTACHMENTS: Supplemental Information

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9905110266 990505

PDR ADOCK 05000498

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EXECllTIVE SUMMARY

South Texas Project Electric Generating Station, Units 1 and 2

NRC Inspection Report No. 50-498/99-06; 50-499/99-06

This inspection included aspects of licensee operations, maintenance, engineering, and plant ,

support.L The report covers a 6 week period of resident inspection, supported by a regional )

. projects inspector.

Ooerations

-a  : When a switchyard breaker failed, Unit 2 experienced a loss of offsite power to Trains B l

and C equipment. The output breaker for Standby Diesel Generator 22 failed to close 1

automatically because an essential chiller breaker cell switch failed to provide a

necessary permissive input. Operators had failed to recognize that the diesel had been

- inoperable for 2 weeks because they did not perform the procedurally required checks.

This,was a violation of Technical Specification 6.8.1. This Severity Level IV violation is

being treated as a noncited violation, consistent with Appendix C of the NRC

Enforcement Policy. This noncited violation is in the licensee's corrective action .

~ program as Condition Report 99-3690 (Section 01.2).

During the loss of offsite power to Unit 2 Trains B and C, operators quickly recognized

that the diesel breaker failed to shut automatically and manually shut it to restore power

to Train B equipment. While this action was appropriate, it was in conflict with the loss

of bus procedure. This loss of bus procedure was generic to all buses and, as a result, 1

was very long, cumbersome to use, and did not place a priority on restoring offsite

power to the engineered safety feature buses. This was a violation of 10 CFR Part 50,

Appendix B, Criterion V, for failure to follow procedures. This Severity Level IV violatien

is being treated as'a noncited violation, consistent with Appendix C of the NRC

Enforcement Policy. This noncited violation is in the licensee's corrective action

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program as Condition Report 99-3713 (Section 01.2).

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  • Operators did not understand the Technical Specification requirements for supplying

offsite power to the engineered safety feature buses. As a result, they failed to enter

Technical Specification 3.0.3 and take the required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action to prepare to shut the ,

plant down when offsite power was lost to Trains B and C while Standby Diesel

Generator 22 was inoperable. When the Technical Specification 3.0.3 entry was

recognized, operators incorrectly concluded that offsite power requirements were being >

met. However, compliance was not restored for another hour and a half, when offsite

power was connected to Trains B and C. The inspectors noted that reconstruction of

the event, particiularly decision making, was significantly hampered because operators

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. did not make log book entries or record adequate notes during the event. This was a ,

z violation of Technical Specification 3.0.3. This Severity Level IV violation is being

- treated as'a noncited violation, consistent with Appendix C of the NRC Enforcement

Policy. This noncited violation is in the licensee's corrective action program as

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, Condition Report 99-3690 (Section 01.2).

.. Operators performed well while shutting down Unit 1 for its scheduled refueling outage.

Reactivity manipulations were well controlled, with excellent support by reactor

engineering personnel Evolutions were well briefed and controlled. Operators 1

responded well to a steam generator water level transient caused by a feedwater pump

. controller problem (Section 01.3).

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performed in a well controlled manner. Excellent supervisory oversight provided

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. effective coordination of site activities and ensured the safe execution of this important

evolution. Detailed procedures effectively implemented relevant corrective actions and

commitments. Contingency actions were briefed in detail and assigned to specific

personnel and equipment was prestaged. Significant precautions were taken to inform

. personnel of the restrictions of activities to protect critical equipment (Section 01.4).

  • - Licensed operator requalification evaluated scenarios were observed to challenge :

operators. Each crew observed demonstrated appropriate accident response, event

classification, and prompt reporting (Section PS.1). )

Maintenance '

  • - . Performance of maintenance and surveillance activitics was good. The Unit 2 solid

state protection system testing was performed in a cautious, deliberate maner with

thorough preparation and excellent support from system engineering and maintenance

personnel (Section M1.1).

-* ' New fuel receipt inspections in Unit 1 were well conducted, utilizing proper supervision

and procedural controls. However, fuel movements within the spent fuel pool in Unit 2

were not controlled as well. A fuel bundle was placed in a storage location that

contained used fuel pool filters. The fuel bundle was undamaged, but the filters were .

compressed, making them difficult to remove. The licensee had not documented the  !

storage locations of the filters and had not coordinated ~ storage of the filters with fuel

storage. No violations of NRC requirements were identified (Section M1.2).

the only available level indicator (a sightglass) to indicate lowering level. A test

boundary valve with known seat leakage allowed test pressure to affect the level i

indication. Test personnel did not evaluate the impact of the leak when the test was

rescheduled to be performed during the period when the sightglass was required for

plant control (Section M4.1).

Enaineerina

  • Several engineering calculations performed in support of the Unit 1 outage were

reviewed and assessed to be of good quality. However, decay heat calculations

. performed in support of an earlier entry into a midloop condition were completed late in

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- the outage preparation process, and the outage schedule was built assuming the

calculations would demonstrate adequate heat removal capability (Section E2.1).

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  • :The licensee successfully implemented a modification to the rod control system to

minimize unnecessary automatic rod motion due to hot-leg temperature streaming. The

10 CFR 50.59 evaluation was clearly written, and comprehensive and adequately

addressed applicable accidents analyses. The postmodification testing was appropriate

' for the modification (Section E2.2).

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' Plant Sucoort

training. The emergency response organization was appropriately focused on accident

mitigation and measures to protect public health and safety. The licensee's emergency

facilities were in good working condition (Section PS.1)

.. Significant improvements over previous outage performance were demonstrated in dose . -

reduction and contamination control. Specifically, the licensee implemented several

ALARA and engineering controls including: mockup training, low dose waiting areas,

newly manufactured shielding, tents on the steam-generator platforms, and covered

floor grating areas to prevent spread of contamination (Section 01,4).

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Report Details

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On March 27, the plant was shut

down for its scheduled refueling outage and remained shutdown for the remainder of the

inspection period.

Unit 2 operated throughout the inspection period at 100 percent power. The unit experienced a

partialloss of offsite power on March 12 when a switchyard breaker experienced a fault. This

resulted in loss of offsite power to Trains B and C equipment. Power was promptly restored via

the standby diesel generators.

I. Operations

01 Conduct of Operations

-01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of

ongoing plant operations. In general, the conduct of operations was professional and

safety conscious; specific events and noteworthy observations are detailed in the

sections below.

-01.2 Partial Loss of Offsite Power in South Texas Project Unit 2

a. Insoection Scoce (93702,71707)

Unit 2 experienced a partial loss of offsite power. Inspectors responded to the control

rooms of both units to determine the impact and observe operator response. The

inspectors reviewed reconstructed operator logs, response procedures, completed

surveillance data sheets, and the licensee's Event Review Team report. The event was

discussed in detail with the plant operators involved. The inspectors reviewed the tag-

out for Essential Chiller 21B and the procedure for racking out breakers.

b. Observations and Findinas

' Event Summary

At 2:12 p.m. on March 12, the load dispatcher attempted to restore one of the offsite

power lines that supplied the South Texas Project's switchyard. When Breaker Y640

was opened, the breaker experienced a fault. Protective relaying actuated to open other

switchyard breakers and the faulted breaker was deenergized. This resulted in

deenergizing the south switchyard bus and the Unit 2 standby transformer, which was

providing power to Trains B and C engineered safety feature (ESF) buses.

Unit 2 operators quickly recognized the loss of power to the south bus. Standby Diesel

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Generators (SDGs) 22 and 23 automatically started. SCG 23 sequenced loads as

expected; however, operators quickly recognized that the SDG 22 output breaker failed

to close and, as a consequence, the engine had no cooling water pump available.

Operators quickly took manual action to close the output breaker and observed that

Train B loads sequenced on automatically.

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Spent fuel' pool cooling was lost for approximately 1% hours and caused a less than 2*F

heatup. Containment cooling automatically shifted from chilled water to component

cooling water as designed, resulting in slightly elevated containment temperature and

pressure; operators responded appropriately to correct this condition. Reactor letdown

isolated, but was promptly restored; the resulting pressurizer level increase

(approximately 9 inches) was corrected. Offsite power to the deenergized buses was

restored from the Unit 1 standby transformer at 3:30 p.m. Trains B and C were then l

transferred to offsite power, and SDGs 22 and 23 were secured by 5:30 p.m.

The inspectors observed the impact of the switchyard transient on Unit 1. Reactor

letdown isolated but was promptly restored, with a corresponding small increase in

pressurizer level. . Several heating, ventilation, and air conditioning systems tripped and

were promptly restored. Power availability was verified by the operators.

Failure to Enter Technical Specification Required Shutdown Action Statement '

As a result of losing power to two trains of ESF buses from offsite and the failure of

SDG 22 to pick up its loads, the plant was in a condition prohibited by Technical

Specifications and Technical Specification 3.0.3 became applicable. Technical

Specification 3.0.3 requires that within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, actions shall be initiated to place the unit

in a mode in which the specification does not apply (i.e., shutdown). The prohibited {

condition was removed when offsite power was restored to Train B at 5:06 p.m. '

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Operators initially misunderstood the Technical Specification requirements. They

L conferred extensively with licensing personnel and concluded at about 4:30 p.m. that

Technical Specification 3.0.3 was entered at the start of the event, but inappropriately

concluded that the condition was rernoved when offsite power was available (but not >

restored) to the ESF buses. This resulted in continuing to be in a condition prohibited by

Technical Specifications longer than necessary.

Failure to recognize entry into a condition prohibited by Technical Specifications and

initiate action to place the unit cold shutdown was a violation. This violation will not be

cited in accordance with Appendix C of the NRC Enforcement Policy. This noncited

violation is in the licensee's corrective action program as Condition Report 99-3690 ,

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(NCV 499/99006-01).-

Cause of SDG 22 Being Rendered inoperable

The licensee initiated troubleshooting and an Event Review Team investigation to

' determine the cause of the SDG 22 output breaker failing to close automatically. The

licensee' determined that the breaker for Essential Chiller 21B was not providing proper

input to the SDG 22 breaker closure permissive circuit. This circuit required that the

loads be stripped from the bus before reenergizing the bus from the SDG To satisfy

the logic, Essential Chiller 218 was required to have its breaker either open or racked

out.

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The licensee also determined that the breaker had been racked out for 2 weeks for

. maintenance and that the switch that was supposed to sense the breaker position did

not operate properly. This condition rendered SDG 22 inoperable for 2 weeks before it

was recognized. The licensee's procedure for racking out breakers, OPOP01-AE-0001,

Revision 1 " Circuit Breaker Operation," required that operators verify proper indication -

. that applicable breakers were racked out by checking computer indications prior to

deenergizing control power. The inspectors determined that Tagout B4387, which

racked out the breaker and tagged it, did not specify performing the switch checks.

Operators misunderstood the intent of the checks and concluded in this case that it was

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acceptable to perform the check during restoration from the work. Failure to follow )

Proceduro OPOP01-AE-0001 was a violation. This violation will not be cited in

accordance with Appendix C of the NRC Enforcement Policy. This noncited violation is

in the licensee's corrective action program as Condition Report 99-3690  !

(NCV 493/99006-02).

Documentation and Procedure Problems

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The inspectors noted that, throughout the event response, no control room log entnes

were made. individual operators kept informal and incomplete notes of major events.

The log was recreated some time after inspectors left the control room at 5:40 p.m. The

inspectors observed this practice during the previous inspection in the simulator and  ;

- documented the observation in NRC Inspection Report 50-498/99-02; 50-499/00-02.

The practice of not formally recording events and limiting condition for operation entries

in real time was considered to have contributed to the failure to recognize entry into a

required shutdown action.

The inspectors reviewed the surveillance documents for Procedure OPSP03-EA-0002,

Revision 4,"ESF Power Availability," performed during this event. The data sheets used

to verify the required power sources were shown in diagram form. The acceptance

criteria, specified in a different part of the surveillance were clear and correctly reflected

. the Technical Specification requirements. However, during this event, operators did not

correctly correlate the data sheet information with the acceptance criteria. As a result,

they incorrectly concluded that Technical Specification credit could be taken for

restoration of offsite power when offsite power was restored to the 13.8KV buses but not

to the associated 4160V ESF buses. The inspectors concluded that Unit 2 was in

' Technical Specification 3.0.3 from 2:12 p.m. until offsite power was restored to ESF

Bus E2B at 5:06 p.m.

The inspectors noted that Procedure OPOPO4 AE-0001," Loss of Any 13.8KV or 4.16KV

Bus," Revision 13, was the primary procedure used by operators to respond to this

- event. This procedure was more than 100 pages in length, contained 16 addendums,

and was so generic in nature that it was cumbersome to use. This observation was

made in NRC Inspection Report 50-498/98-15; 50-499/98-15 during an earlier loss of

power event. The inspectors noted that the procedure did not convey the appropriate

priority to restore offsite power to the ESF buses. Additionally, when the SDG 22 output

breaker f ailed to close, this procedure inappropriately directed operators to trip the

engine; without resolving the inappropriate procedure step, operators manually closed

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the breaker. This was a failure to follow procedures and is a violation of 10 CFR l

Part 50, Appendix B, Criterion V. ' This violation will not be cited in accordance with

Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective

actica program as Condition Report 99-3713 (NCV 499/99006-03).

c. Conclusions

When a switchyard breaker failed, Unit 2 experienced a loss of offsite power to Trains B

and C equipment. The output breaker for Standby Diesel Generator 22 failed to close

automatically because an essential chiller breaker cell switch failed to provide a

necessary permissive input. Operators had failed to recognize that the diesel had been

inoperable for 2 weeks because they did not perform the required checks. This was an

NCV.

Operators quickly recognized that the diesel breaker failed to shut automatically and

manually shut it to restore power to Train B equipment, inspectors identified that this

action,' whi!e appropriate under the circumstances, was in conflict with the loss of bus ,

procedure. This procedure was generic to all buses and, as a result, was very long,

cumbersome to use, and did not place a priority on restoring offsite power to the ESF

buses. This was an NCV.

Operators did not understand the Technical Specification requirements for supplying

offsite power to the ESF buses. As a result, they failed to enter Technical

Specification 3.0.3 and take the required I hour actions to prepare to shut the plant

down. When the Technical Specification 3.0.3 entry was recognized, operators

incorrectly concluded that offsite power requirements were being met. However,

compliance was not restored for another hour and a half, when offsite power was

connected to Trains B and C. This was an NCV. The inspectors noted that

reconstruction of the event, particularly decision making, was significantly hampered

because operators did not make a single log book entry or record adequate notes

during the event.

01.3 Unit 1 Shutdown and Control Rod Testina Observations (71707)

The inspectors observed the performance of operators while shutting down Unit 1 for its

scheduled eighth refueling outage on March 26-27. This included testing of all control

rods.

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The inspectors observed reactor operators performing reactivity manipulations in

accordance with approved procedures. Reactor engineering provided close support

during both the shutdown and rod testing. Reactivity control was enhanced by reactor

engineering through the use of predicted data for the planned shutdown sequence

based on historical data frcm previous shutdowns. These data allowed operators to

better plan reactivity manipulations throughout the complex shutdown sequence.

Formal communication was evident throughout unit shutdown and cooldown. Evolutions

were well briefed and cortrolled. Support personnel were readily available.

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Plant equipment performed well during the shutdown, with several minor exceptions.

The Steam Generator Feed Pump 13 controller did not perform as expected while

operators attempted to shut down Steam Generator Feed Pump 12 and resulted in

water level oscillations in all four steam generators. Operators recognized the problem

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and quickly took action to stabilize water levels and secure Steam Generator Feed

Pump 13 instead of 12.

- The inspectors observed that the shutdown sequence included an aggressive

surveillance testing schedule.- At times, this resulted in large numbers of extra .

personnelin the controls area of the control room. Surveillance testing and main turbine

overspeed testing were performed without problem.

Control rod testing was performed following reactor shutdown to demonstrate that all

rods would insert. This was done in response to past problems. Proper controls were

utilized to ensure that the reactor remained shut down while control rod banks were

withdrawn and inserted. The testing identified four control rod assemblies that did not

fully insert and remained six steps from fully inserted. Each of the problem rods were

Cycle 1 fuel which was at its end of life, and all the control rods were scheduled to be

replaced during the outage. However, each of the problem fuel assemblies had a lower

burnup exposure than previously identified problem bundles. Newer fuel designs have

not exhibited this problem.

01.4 Observation of Unit 1 Reactor Coolant System Midlooo Ooerations

a. Insoection Scone (71707)

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The inspectors maintained continuous onsite coverage during front-end midloop

operations in Unit 1. The inspectors observed operator training, preparations, and

briefings, walked down temporary systems for water level indication and vacuum filling,

and verified that personnel designated to perform contingency actions were trained and

stationed with necessary equipment. Procedures, planning, and oversight were

evaluated prior to reduced inventory operations.-

b. Observations and Findinas

The inspectors observed training for the operating crew scheduled to perform midloop

operations.1 Procedures were walked through and then performed in the simulator.

Contingency scenarios were also covered, although the inspectors noted that the loss of

residual heat removal (RHR) scenario was not a particularly challenging case. Industry

lessons-leamed were discussed.

The inspectors observed that the licensee's procedures governing this complex

evolution were detailed. These procedures were found to effectively implement

corrective actions committed to in response to site and industry events related to

midloop operations. Contingency actions were clearly specified and briefed, and

- designated personnel were stationed and equipment was prestaged. Periodic site

announcements were made to remind personnel of the midioop activities and the

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' additional restrictions on other site activities. . Signs were posted at access points to the

critica! equipment. An operntor was dedicated to venting the residual heat removal

system in the event of loss of level in the reactor vessel. Pipe caps were removed, and

hoses were attached to these vents to minimize any delay.

Operators alertly monitoreci all pertinent instrumentation and performed frequent

verification of parameters among diverse instruments.~ The reactor vessel water level

s!ght glass was monitored by an operator in the containment and on a video monitor in

the control room. Detailed system drawings and operational data were provided to

ensure that operationallimits were maintained. Communications were maintained

between the control room and important field activities throughout the evolution.

- The inspectors reviewed 1he applicable procedures and plans, performed a walkdown of

the accessible critical equipment, and observed control room activities during the

draindown to midloop and the restoration of water level to above the reactor coolant

' loops.

During midloop operations, work activities on the unit were limited to those that did not

impact the operator's ability to control decay heat removal. Work packages were pulled

from the field, reviewed, and only reissued if approved by the shift supervisor and l

midloop coordinator. In spite of these controls, several activities were allowed in the I

control room that had tne potential to distract the operators. An intermediate range

nuclear instrument calibration was performed which resulted in several alarms and in a t

technician in the operation's area of the control room. Troubleshooting activities for a

steam generator level indication problem required sharing the plant computer terminal

- between the technician and the operators. Neither activity interfered with the midloop

operation.

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Thi draindown was performed slowly and cautiously and in accordance with the

procedure. ' As each heated junction thermocoJple in the reactor vessel level system

was uncovered, agreement with the " slinky" sight glass level indication was verified.

Agreemen; with other indications was also verified.

When water level was lowered to the top of the loops, instrumentation and contro!

technicians unsuccessfully attempted to place the hot-leg narrow-range level

instruments in sen ice and get agreement among indicatore. The draindown was

suspended. After 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the licensee concluded that insufficient nitrogen had been

injected into the s'.eam generator U-tubes. As a result, draindown was significantly

slowed. In the process of verifying the instrument lineup, technicians inadvertently

removed the hot-;eg narrow-range level instruments from service before the error was

discovered. ' Level agreement was then restored arnong instruments.

Supsrvisory oversight of the evolution was excellent. Outage management actively

provided important coordination of all site activities to ensure that equipment important

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for midloop operations or contingency actions were maintained available. Senior

licensed operators were assigned to supervise the operational aspects of the evolution

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. which included coordinating entry into the primary side of each steam generator to

install nozzle d.ams and ensuring that a hot-leg vent path was always available.

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The steam generator work activities were well performed. Dose control improvements

significantly reduced radiation exposure over previous evolutions. Contamination

controls were also effectively improved. Specifically, the licensee implemented several

- ALARA and engineering controls including: mockup training, low dose waiting areas, 1

- improved shielding, tents on the steam-generator platforms, and covered floor grating

areas to prevent spread of contamination.
c.  ! Conclusions

inspectors concluded that front-end reactor coolant system reduced inventory and

midloop optsrations were performed in a controlled manner. Excellent supervisory.

, oversight was provided which effectively coordinated site activities and ensured the safe

. execution of this important evolution. Detailed procedures effectively implemented

relevant corrective actions and commitments. Contingency actions were briefed in detai! .

and assigned to specific personnel, and equipment was prestaged. Significant

precautions were taken to inform personnel of the restrictions of activities to protect

critical equipment. Significant improvements over previous outage performance were

demonstrated in dose reduction and contamination control. Specifically, the licensee

implemented several ALARA and engineering controls including: mockup training, low

t ' dose waiting areas, improved shielding, tents on the steam-generator platforms, and

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covered floor grating areas to prevent spread of contamination.

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03 Operations Procedures and Documentation

-03.1 Engigpred Safetv Feature (ESF) Systems Walked Down (71707)

The inspectors used Inspection Procedure 71707 to walk down accessible portions of

the folic, wing ESF systems:

. Hydrogen Recombiners (Unit 1)

L Containment Spray System (Unit 1)

. . Fuel Handling Building Ventilation Exhaust System (Units 1 and 2)

. Equipment operability and material condition were acceptable in all cases. The

inspectors verified that the systems were aligned properly for the existing mode of

' operation. The inspectors conducted daily control board walkdowns to verify that ESF

systems were. aligned as required by Technical Specification for the existing operating

mode, that instrumentation was operating correctly, and that power was available.

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ll. Maintenance l

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M1 Conduct of Maintenance

M1.1 Maintenance and Surveillance Observations l

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a, inspection Scooe (62707. 61726) j

The inspectors observed all or portions of the following maintenance and surveillance

activities. For surveillance tests, the procedures were reviewed and compared to the

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Technical Specification surveillance requirements and bases to ensure that the

procedures satisfied the requirements. Maintenance work was reviewed to ensure that

. adequate work instructions were provided, that the work performed was within the scope

of the authorized work, and that it was adequately documented. Work practices were

also observed. In each case, the impact to equipment operability and applicable

Technical Specifications actions were independent!y verified.

Surveillances observed: l

  • OPSP03-DG-0003, " Standby Diesel Generator 13 Operability Test" (Unit 1)
  • OPSP03 EA-0002,"ESF Power Availability"(Unit 2) l
  • OPSP03-SB-0001, " Steam Generator Blowdown System Valve Operability Test" l

(Unit 2)

Maintenance activities observed:

  • New Fuel Receipt and inspection (Unit 1)
  • Fuel Handling Bu!! ding Ventilation Modification (Unit 1)
  • Solid State Protection System Logic Train S Functional Test and

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' ableshooting (Unit 2)

b. Observations and Findinas

The inspectors observed that the work performed during these activities was thorough

and detailed. Work observed was performed within the scope of the work package.

Technicians were experienced and knowledgeable of their assigned tasks. Equipment

manipulations during tests were very well controlled. Craft and operators utilized good

self-verification techniques. Communication between control room operators and plant

operators and technicians in the field were precise and sufficiently detailed. Supervisory

oversight was evident, and engineering personnel frequently were observed

participating in and observing tests. The inspectors verified that surveillance activities

satisfied Technical Specifications requirements.

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On February 27, the inspectors observed licensed operators and instrumentation and

controls technicians perform a functional test of the solid state protection Train S

system. The test was performed utilizing Temporary Surveillance

- Procedure 2 TSP 03-SP-0002, Revision 1, "SSPS Logic Train S Functional Test." This

test was performed to verify that the solid state protection system (SSPS) test circuit

would detect a failed card with an intermittent low voltage condition previously identified

in the Unit 2 Train S circuit. The low voltage condition was identified by the licensee

during troubleshooting for a failed card.

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The inspectors reviewed the procedure and determined that the test methodology was

to simulate a failed card and determine if the installed semiautomatic test circuit would

detect the induced failure. The procedure also included two contingency tests to assure

system operability if the test card failed to detect the induced failure. The inspector i

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reviewed Unreviewed Safety Question Evaluation 98-20456-6 developed for the

performance of the test and determined that it was thorough and satisfied the

requirements of 10 CFR 50.59.

The inspectors observed licensee preparations for the test. Reactor operators,

technicians, and the system engineer performed a detailed walkthrough of the

procedure. As a result, two minor errors were identified and corrected in the procedure.

The prejob briefing in the control room was detailed and focused on risk to plant

operation. During test performance, communications were precise and deliberate. The

system engineer and maintenance supervisor provided direct support and oversight.

Switch manipulations were performed by a reactor operator with direct supervision by a

senior reactor operator. The test circuit initially failed to detect the induced failure;

however, the system engineer determined that the low voltage condition was not

present. As a result, the test was considered inconclusive due to the intermittent nature

of the low voltage condition. However, the test was able to confirm system operability.

Further troubleshooting was scheduled for the Unit 2 refueling outage in the fall of 1999.

c. Conclusions

Performance of maintenance and surveillance activities was good. The Unit 2 SSPS

testing was performed in a cautious, deliberate manner with thorough preparation and

excellent support from the system engineering and maintenance.

M1.2 Soent Fuel Pool Activities

a. Inspection Scoce (71707)

The inspectors observed fuel movement activities in the Units 1 and 2 fuel handling

buildings. These activities included new fuel receipt in Unit 1 and spent fuel bundle

movements in preparation for boraflex panel removal in Unit 2.

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b. Observations and Findinos .

Unit 1 received new fuel for the upcoming refueling outage during this inspection period.

The inspectors observed that work involving new fuel receipt, inspection, and storage

was systematic and efficient. New control rod assemblies were also received and

inspected. The fuel receipt was adequately supported by engineering, operations,

maintenance, and health physics personnel. The inspectors noted good coordination

between the different plant departments. New fuel was inspected and handled in

accordance with procedures. The new fuel was visually inspected for defects and

foreign objects. Following inspection, the fuel was placed into storage in the spent fuel

pool.

On February 22, while moving fuel within the Unit 2 spent fuel pool for boraflex

replacement, operators observed that the load cell reading increased suddenly by

500 pounds. This was indicative of binding. They stopped and lowered the bundle back

into its cell. The load cell remained reading 500 pounds high and was reset after

consulting with reactor engineering personnel. The load cell was verified to be reading

correctly by the use of a dummy bundle, and fuel movement was resumed. The bundle

was successfully moved without further incident.

On March 3,1999, two used fuel pool filters were compressed in a fuel storage rack

while attempting to insert a fuel assembly. Licensee management suspended fuel

movement. The fuel assembly was not damaged. Debris from the filter was released

within the pool. The Health Physics department successfully removed all material on

the surface. Investigation revealed other cells with unaccounted filters. A total of nine

filters were removed and stored in another location. The filters which were compressed

remained in Cell 2B42 at the conclusion of the inspection period. Procedural

requirements for the inventory and storage of filters in the spent fuel pool had changed;

however, the filters had not been removed when the inventory location changed.

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Corrective actions implemented by the licensee due to this event included: positive

verification of empty storage locations in the spent fuel pool before movement, a prejob

brief of this event for crews and reactor engineers, and contingency plans. The licensee

was working toward the removal of the filters from Rack Location 2B42.

c. Conclusions

New fuel receipt inspections in Unit 1 were done well, utilizing proper supervision and

procedural controls. However, fuel movements within the spent fuel pool in Unit 2 were

not controlled as well. A fuel bundle was placed in a storage location that contained

used fuel pool filters. The fuel bundle was undamaged, but the filters were compressed,

making them difficult to remove. The licensee had not documented the storage

locations of the filters and had not coordinated storage of the filters with fuel storage.

No violations of NRC requirements were identified.

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M1.3 Offsite Power Reliability Review (62707)

The inspectors reviewed the licensee's reliability / availability _ data for offsite power

transmission lines and compared it with the licensing basis stated in the Updated Final  !

Safety Analysis Repor1(UFSAR). Section 8.2 of the UFSAR stated in part that, based

on a historical review of Houston Lighting and Power 345 kV transmission system data,

the expected frequency of instantaneous line outages was 2.14 outages per year per-

100 circuit miles. An instantaneous outage was defined as an outage in which the line

circuit breakers tripped and reclosed, reenergizing the circuit in less than one second.

The UFSAR also defined a sustained outage as an outage that required manual

reciosing of the circuit breaker to reenergize the circuit. The UFSAR stated frequency

for sustained outages was 1.34 outages per year per 100 circuit-miles.

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During this inspection period, the licensee experienced an unusual number of unplanned

line outages including four sustained outages on March 9.. In their evaluation, the -

' licensee attributed the increased outage frequency to flashover of dirty line insulators.

The inspector reviewed the available line outage data for the 345 kV transmission lines i

that connect to the South Texas Project switchyard. The system engineer stated that

the data was generated quarterly and that the best available data was through the end

of 1998. The inspector noted th;.1, although the instantaneous outage frequency was

within the licensing basis, the sustained outage frequency was 1.34, slightly higher that

the frequency stated in the UFSAR. The inspectors will review the data for the first

quarter of 1999 when it is available as well as the licensee's efforts to maintain offsite

power reliability consistent with their licensing basis. This item will be tracked as an

inspection followup item (IFl 50-498;499/99006-04).

M4 - Maintenance Staff Knowledge and Performance

( M4.1 E Maintenance Test Caused Faultv Reactor Water Level lndication (93702)

Unit 1 experienced an indicated reactor water level transient following midloop with tha

reactor flooded up near the head flange. On April 1, a localleak rate testing boundary

valve experienced seat leakage, and test pressure leaking out of the test boundary

- caused indicated level on the reactor water level sight glass, the only available indicator,

to trend downward. Operators responded conservatively in accordance with

procedures. Test personnel were quick to report that their testing could have caused

_ the observed indications. When test pressure was' removed, water level indication

' returned to expected levels. Although the leaking valve had known seat leakage, it was

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not evaluated for potential impact on reactor water level indication during the test. This

evaluation was originally not needed because the test was originally scheduled to be

performed during the period when the sight glass was not required for plant control.

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111. Enaineerina

E2 . Engineering Support of Facilities and Equipment ,

E2.'1 : Enaineerina Sunoort for Unit 1 Ou_laae Preparations (37551)

The inspectors reviewed the following calculations performed by engineering in support i

of performing midloop earlier after shutdown than previously experienced:

99-FC-003 " Spent Fuel Pool Heatup Analysis for 1RE08"

99-FC-001 ' "RCS Heatup Rates During 1RE08 Mid-loop Operation"

99-RC-002 "1RE08 Mid-loop RHR Performance Evaluation"

NC-7137 " Bounding RHR Mid loop Performance Evalation"

These engineering calculations were detailed and complete. Appropriate conservatism

and reasonable assumptions were used in each example. The decay heat removal  !

calculations were used to support planned entry into reduced inventory and midioop l

conditions earlier during the outage than had previously been performed. The

calculations demonstrated that adequate heat removal capability existed with two trains

of RHR. However, the inspectors noted that the calculations were completed late during

the outage preparation process and that the outage schedule was built assuming the

calculations would demonstrate adequate heat removal capability.  !

E2.2 Desian Chanae to Minimize Unnecessarv Automatic Control Rod Motion ,

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a .' L Inspection Scope (37551)-

The inspectors reviewed the licensee's 10 CFR Part 50.59 Evaluation for Design-

Change Package 95-11217-10," Automatic Rod Control Rod Movement Minimization '  :

During Normal Operations" and discussed the purpose, implementation, and

postmodification testing with engineering personnel.

b.' Observations and Findinas

-The licensee experienced unnecessary automatic control rod motion periodically during i

steady state operation. This was an industry issue that was caused by localized

temperature variations in the hot-leg known as " hot leg temperature streaming." The

licensee consulted with Westinghouse and decided to modify the system response by

revising the time constants in the rod control circuitry. This method had been

. . implemented successfully at other Westinghouse plants.

The 10_CFR Part 50.59 evaluation relied on a Westinghouse analysis which determined

that the modified rod control system would continue to operate as described in the

UFSAR. Applicable accident analyses which relied on rod control system automatic

Loperation for mitigation were appropriately addressed in the licensee's evaluation. The

evaluation was clearly written and comprehensive.

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Postmodification testing consisted of circuit card checkouts on a test bench and

observation of the rod control system after placing the system in automatic. The bench

tests were adequate to verify acceptable performance. No spurious control rod motion

occurred after the modification was implemented. The inspectors noted that the

duration of monitoring in Unit 1 was limited due to the beginning of the refueling outage.

c. Conclusion

The licensee successfully implemented a modification to the rod control system to -

minimize unnecessary automatic rod motion due to hot-leg temperature streaming. The

10 CFR Part 50.59 evaluation was clearly written and comprehensive and adequately

addressed applicable accidents analyses. The po.stmodification testing was appropriate

for the modification.

IV. Plant SUDDort

P5 Staff Training and Qualification in Emergency Preparedness

PS.1 Emeraency Preparedness Trainina Observations

a. Insoection Scooe (71750)

The inspectors observed licensed operator requalification evaluated simulator sessions

for emergency response, as well as a site emergency response team drill on March 3.

b. Observations and Findinas

The inspectors observed licensed operator requalification for three separate crews that

were being evaluated for emergency response during simulator sessions. The

inspectors observed that the simulator sessions were challenging scenarios, in each

. case, operators correctly classified each event and ensured timely reporting to outside

agencies. Several support personnel were new to their emergency response roles, but

each was effective due to coaching from their respective shift supervisors.

The scenario included a partialloss of electrical power. The inspectors observed that

this portion of the scenario had a situation that was very close to an actual plant event in

Unit 1 in June of 1998. NRC inspection Report 50-498/98-15 documented inspector

concerns about Procedure OPOPO4-AE-0001, " Loss of Any 13.8KV or 4.16KV Bus,"

Revision 13,in responding to that event. During the simulator sessions, the inspectors

noted that the procedure remained unimproved; operators did not really use the

procedure before the scenario progressed to the point where a manual reactor trip was

necessary.

The emergency response organization training drill was conducted using a scenario

similar to that used for the operators. Some training value was lost by not using the

simulator during the drill; scripted data was used rather than realtime computer

information. Some training value was lost by simulating the dispatching of repair teams,

rather than actually sending them.

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The inspectors observed operations in the Operations Support Center. Priorities were

clearly communicated. Briefings to repair teams were thorough, although very time

consuming. Since the scenario was scripted, the slow dispatching of repair teams

impacted scenario progression at times.

The inspectors observed that personnel in the Technical Support Center performed as a

' team in responding to the exercise scenario conditions. Technical Support Center .

staffing and activation was prompt, and command and control was established

effectively. Plant conditions were analyzed and evaluated for prioritization and

coordinated with the Operations Support Center. The use of status boards was effective

in monitoring key plant parameters and conditions. The inspectors observed good

coaching of closed loop communications for personnel not accustomed to closed loop

communication.

The inspectors observed that personnel in the Emergency Operations Facility were )

appropriately focused on potential offsite release mechanisms. When the simulated

situation degraded, personnel projected when the situation would require entry into a

general emergency and conservatively declared the escalation before actually reaching

it. Appropriate protective action recommendations were made.

The licensee's emergency response facilities were maintained in good condition.

Communications and other emergency equipment were available and in good working

condition. Procedures and reference material were current and readily available,

c. -Conclusions

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An emergency preparedness drill was observed to provide effective training. The

emergency response organization was appropriately focused on accident mitigation and - l

measures to protect public health and safety. The licensee's emergency facilities were

in good working condition.

Scenarios evaluated during licensed operator requalification challenged operators.

Each crew observed demonstrated appropriate accident response, event classification,  ;

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and prompt reporting.

Miscellaneous issues - ,

The Severity Level IV violations listed below were issued in Notices of. Violation prior to

the March 11,1999, implementation of the NRC's new policy for treatment of Severity

Level IV violations (Appendix C of the Enforcement Policy). Because these violations

. would have been treated as noncited violations in accordance with Appendix C, they are

being closed out in this report.

1 Violation number 50-498;499/9706-08 This violation is in the licensee's corrective

action program as CR 97-16443.

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Violation number 50-499/9809-03 This violation is in the licensee's corrective '

action program as CR 9814552.

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V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management on

April 6,1999. Management personnel acknowledged the findings presented. The

inspector asked whether any materials examined during the inspection should be

considered proprietary. No proprietary information was identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

P. Arrington, Nuclear Assurance and Licensing

M. Berrens, Manager, Work Control l

J. Calvert, Manager, Operations Training

T. Cloninger, Vice President, Engineering and Technical Services

W. Dowdy, Manager, Plant Operations Unit 2 -

R. Fast, Manager, Unit 1 Maintenance

T. Frawley, Operations Shift Supervisor

J. Groth, Vice President, Nuclear Generation

E. Halpin, Manager, Unit 2 Maintenance

S. Head, Supervisor Nuclear Assurance and Licensing

J. Johnson, Manager, Engineering Quality

T Jordan, Manager, Systems Engineering

M. Kanavos, Manager, Mechanical and Civil Design Engineering

A. Kent, Manager, Electrical / Instrumentation and Controls, System Engineering

M. Lashley, Manager, Reliability Engineering

D. Leazar, Director, Nuclear Fuel and Analysis

R. Lovell, Manager, Generation Support

R. Masse, Plant Manager, Unit 2

F. Mangan, Vice President, Business Services

M. McBurnett, Director, Quality and Licensing

B. Mookhoek, Nuclear Assurance and Licensing

G. Parkey, Plant Manager, Unit 1

J. Phelps, Manager, Plant Operations Unit 1

T. Powell, Manager, Health Physics

J. Sheppard, Vice President

S. Thomas, Manager, Design Engineering Department

NRC

T. Alexion, STP Project Manager, NRR

P. Kang, Electrical Branch, NRR

R. Smith, OA Branch, NRR

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INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 61726: Surveillance Observations ,

IP 62707: Maintenance Observation

IP 71707: . Plant Operations

IP 71750: Plant Support -

IP 93702: Prompt Onsite Response to Events at Operating Power Reactors

ITEMS OPENED. CLOSED. AND DISCUSSED

Ooened

50-499/99006-01 NCV Failure to recognize entry into Technical

Specification 3.0.3 during loss of offsite power to

two trains with inoperable SDG

50-499/99006-02 NCV Failure to follow procedure requiring checks after

racking out breaker

50-499/99006-03 NCV Failure to have procedure appropriate to the

circumstances for a diesel-generator output i

breaker failure to close

50-499/99006-04 IFl Review of offsite power reliability

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Closed

50-499/99006-01 NCV Failure to recognize entry into Technical l

Specification 3.0.3 during loss of offsite power to

two trains with inoperable SDG

50-499/99006-02 NCV Failure to follow procedure requiring checks after

. racking out breaker

50-499/99006-03 NCV Failure to have procedure appropriate to the

circumstances for a diesel-generator output

breaker failure to close

50-498;499/9706-08 VIO Failure to document a written unreviewed safety

question determination upon installation of the

advance liquid waste processing system

50-499/9809-03 VIO Inappropriate work instructions cause reactor trip

on loss of feedwater to one steam generator

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