ML20234E634

Insp Repts 50-498/87-41 & 50-499/87-41 on 870615-0702. Deviations Noted.Major Areas Inspected:Followup on Allegations & Maint Program

ML20234E634
Person / Time
Site:	South Texas
Issue date:	08/13/1987
From:	Constable G, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20234E605	List: ML20234E604 ML20234E625 ML20234E634
References
50-498-87-41, 50-499-87-41, NUDOCS 8709220459
Download: ML20234E634 (7)

See also: IR 05000498/1987041

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-41 Construction Permits: CPPR-128

50-499/87-41 CPPR-129

Dockets: 50-498 Category: A2

50-499

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

P. O. Box 1700

Houston, Texas 77001

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

Inspection At: STP, Matagorda County, Texas

Inspection Conducted: June 15 through July 2, 1987  !

Inspector: y

E M. McNeill, Reactor Inspector, Project

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Date

Section A, Reactor Projects Branch

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Approved: . . . - 9'//J )

(TW ConstaMeMbief, Project Section C Ddte/

Reactor Projects Branch

Inspection Summary

Inspection Conducted June 15 through July 2, 1987 (Report 50-498/87-41;

50-499/87-41)

Areas Inspected: Routine, announced inspection of followup on allegations and

maintenance program.

Results: Within the areas inspected, one deviation was identified (failure of

the maintenance program to meet the FSAR quality requirements, paragraph 3).

8709220459 870917

PDR ADOCK 05000498

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DETAILS

1. Persons Contacted

Principal . Licensee Personnel

W. S. Blair, Maintenance Support Supervisor 4

M. ' H. Carnley, Instrument & Control -(I&C) Supervisor i

• J. E. Geiger, General Manager, Nuclear Assurance )

• J. Green,OperationsQualityAssurance(QA) i

L Guthrie,

• I. .. SAFETEAM Manager j

• B. D. Hall, Department Manager, SAFETEAM ]

R. D. Hall, Lead Maintenance Specialist

A. W. Harrison, Supervisor, Project' Engineering

• S.14. Head, Lead Project Compliance Engineer

S. E. Hill, Maintenance Supervisor, Technical / Support

T. Jenkins, Start Up Engineer

T. J. Jordan, Project QA Manager

• W. H. Kinsey, STP Plant Manager  ;

• M. A. Ludwig, Maintenance Manager  !

D. W. Morgan, I&C Foreman  !

G. Morrow, Start Up Engineer i

V. P. Portell, QA Specialist

P. B. Travis, I&C. Technical Supervisor  !

C. M. Turner, Fire Protection Staff Engineer {

F. L. Wiens, Maintenance Supervisor i

• M. R. Wisenburg, Deputy Project Manager  !

Bechtel Power Corporation

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A. O. Guidry, Fire Protection Group Leader ]

R. W. Miller, Site Project QA Engineer l

J. O' Hair, Operation Plant Services Project Engineer {

Ebasco Service Inc.

K. Gilkerson, QA Engineer

R. E. Powe, Lead QA Engineer Systems

J. H. Smith, Lead Mechanical Supervisor

• Denotes those individuals attending an exit interview with the NRC

inspector.

2. Followup on Allegations

(Technically Closed) Allegation 4-87-A-038: This allegation was that

Quality Control (QC) controls had broken down in that construction personnel

had dismantled Class III instruments and tubing of Diesel Generator No. 13

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(Bay C) without QC coverage and further that QC decided to have the lines '

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' reconnected and then disassembled with QC witness. The allegation had not

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been addressed as a SAFETEAM concern. There was a SAFETEAM concern

somewhat similar in regard to QC inspection points on a startup work

request (SWR). That concern, No. 11344, was substantiated.

The NRC inspector found that after turnover of equipment to operations,

work on equipment is controlled by SWRs or temporary alteration tags. In

regard to. temporary alterations, there are no QC requirements specified in

general by nature of the type of activity in question (nonpermanent). In

the Record Management System (RMS), a file is maintained of SWRs and their

associated work packages by equipment or component. Based on the

identification supplied by the alleger, the file for Diesel No. 13 was

reviewed by the NRC inspector. From that review, a list of inspectors

involved in SWRs and their work packages was established. These

inspection personnel were interviewed in regard to missed inspection

points. From the event description supplied by the alleger, the time

frame in question and the identification of personnel involved supplied by ,

the alleger, these inspectors confirmed that the event in question did i

indeed occur; however, it was on Diesel No.12 in Bay B. The hold points

on SWR No. 17032 and its associated Work Package No. 1DG02I6078 were

violated. The violation of hold points was documented in Nonconformance

Report (NCR) No. SJ-03564 dated May 23s 1987. As corrective action, a

pipefitter, who was the cause of the violation, was suspended for 3 days

and the 13 associated personnel were retrained on the requirements in

question. The allegation was substantiated; however, the problem was

self-identified, acceptable corrective action was taken prior to this NRC

inspection, and the problem appears to be of no consequence.

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(Technically Closed) Allegation 4-87-A-041: This allegation was that

there were welding discrepancies on the saddles of the main steam headers.

This allegation was not addressed to SAFETEAM. Based on a review of

SAFETEAM files, it appears there was not a concern of a similar nature

registered.

The NRC inspector found that the main steam lines, as they exit the

reactor containment, enter into rooms called the isolation valve cubicles.

In the isolation valve cubicles, each main steam line is called a main

steam header. From the main steam header, the safety relief valves branch I

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off. These branches, however, do not have saddles associated with them.

The type saddles in question are branch connection reinforcement such as

identified in ASME Code NC-3643.3.

After contacts with the vendor personnel referred to by the alleger and I

subsequent contacts with the alleger, it was established that the saddles

in question were part of an early design circa 1982. Shortly after

project turnover from Brown & Root to Bechtel, the main steam headers were

redesigned to a forged header design thus eliminating the need for saddles

at the safety relief branch connection. Inspection of the main steam

header by the NRC inspector failed to find any saddles of any type as

identified by the alleger. Based on interviews of Bechtel and vendor

personnel, it was established that there were some discussions of the

earlier design and its feasibility. It would appear that the alleger is

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recalling design discussions of the earlier design of the main steam f

header. This allegation was not substantiated.

(Technically Close'd) Allegation 4-87-A-052: This allegation was that

SAFETEAM investigations have a narrow focus and as such fail to study root  ;

causes and generic implications. An example of a SAFETEAM investigation j

of harassment and intimidation was given.

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The NRC inspector reviewed the SAFETEAM files on the example given,

Concern No. 58405. It was established that this concern did establish

that harassment and intimidation did occur and that the generic implications

such as what others may have been harassed and intimidated were not

documented. This concern had been investigated by Ebasco just prior to

the implementation of the SAFETEAM program.

The NRC inspector further reviewed all concerns registered to date dealing

with harassment and intimidation of QA/QC personnel or others that were

investigated by SAFETEAM. Particular attention was paid to 24 concerns

where there was some measure of substantiation or a recommendation made as

a result of the investigation. Two concerns (Nos. 10375 and 10827) were

identified by the NRC inspector that had been investigated by SAFETEAM and

were clearly cases of harassment and intimidation. Concern No. 10375

documented harassment and intimidation of an inspector; however, there was ,

no record or recommendation of a generic investigation. The NRC staff

review observed that the SAFETEAM charter did not specifically require l

the SAFETEAM to evaluate root cause or generic implications of

substantiated allegations; however, these aspects were considered when

technical concerns were identified. Concern No. 10827 documented harassment

and intimidation of a pipefitter, and there was a recommendation to review

the problem in general. HL&P did review the problem in regard to the

quality dimension of the problem. However, the review of the generic

aspects the harassment and intimidation dimension performed by Ebasco was

not documented. This allegation was substantiated, in that, SAFETEAM

records did not consistently' reflect that their reviews had been conducted

to determine root cause and generic implications.

This is viewed as a program weakness and does not involve a violation of

NRC regulations. The overall assessment of the HL&P SAFETEAM program was

determined to be acceptable (NRC Inspection Report 50-498;499/87-45).

HL&P, in a letter dated July 15, 1987 (Observation No. 23), committed to

take appropriate corrective action. These corrective actions are l

acceptable to'the NRC staff.

3. Maintenance Program

The objective of this inspection was to determine whether the licensee has

developed and implemented a maintenance program. In particular, the

implementation of the preventative maintenance (PM) program in the I&C

discipline was inspected. In this regard, the STP FSAR, the Quality

Assurance Program Description, Revision 18, dated June 12, 1987, and

Procedure No. DPGP03-AM-0002, Preventive Maintenance Program, Revision 9,

were reviewed by the NRC inspector.

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The NRC inspector found that the current program requires PM on all

safety-related equipment and that which is important to safety, such as

fire protection, radwaste, post-accident monitoring, and qualified display

processing systems, as well as seismic two over one (II/I) supports,

containment penetrations, and category II instrumentation. When the NRC

inspector attempted to verify the implementation of the above program on

these systems important to safety, it was established that not all of the

PMs on the fire protection system were treated.the same as those that are

safety-related. An example of this was PM IC-1-FP-86008940, Revision 0,

dated April 15, 1986. The licensee identified that they had identified '

some 1900 PMs as such. A review of the revision history'of the PM

procedure by the NRC inspector found that on December 22, 1986, the

procedure was revised to clarify the program requirements and add the

qualified display processing system and category II instrumentation. At

STP, a Bechtel. quality classification system of nine levels was used for

construction. The nine levels generally break down as follows: levels 1

through 3 correspond to ASME class 1 through 3; level 7 corresponds to

important to safety; levels 8 and 9 correspond to nonsafety and nonquality; i

level 4 is a combination of level 1 through 3 and IEEE_ class 1E; level 5 is i

a combination of levels 1 through 4 with levels 7 through 9; level 6 is a

combination of levels 7 through.9, level 8 differs from 9 because of i

equipment history. The fire protection system, as designed and installed

at STP, is a system with levels 7 and 9 equipment together in the same

system. Prior to December, the PM procedure read such that the level 9

equipment in the fire protection system was not treated like the level 7,

meaning the same as safety-related. The NRC inspector also found that the

ProcedureOPGP03-ZM-0003,MaintenanceWorkRequest(MWR) Program,wasalso

revised at the same time in the same manner. Therefore, prior to the

revision in question in December 1986, the PM and MWR procedures failed to

comply with the FSAR requirements in Section 3.2 which identified a blanket

coverage of the fire protection system with quality requirements. The

difference for PMs and MWRs being treated the same as safety-related or

not, is whether or not QA approved procedures were used and whether or not

QC inspection points were applied.

In addition to the above procedural problem, the revised procedures were

not implemented fully because personnel understood that existing PMs and

MWRs were grandfathered. The NRC inspector verified that some PMs

(IC-EW-86003360,IC-EW-86005078,andIC-1-SH-86003490) and MWRs

(FP-87004268andFP-87005961) were performed without QA/QC involvement

after December 1986. As a result, HL&P has identified that across all

disciplines (I&C, electrical, and mechanical), approximately 300 MWRs and

460 PMs were performed without QA/QC involvement. Also, approximately

1960 PMs have been written which require revision for QA/QC involvement so

that they are treated as safety-related. Most of the above PMs and MWRs

were in the I&C discipline. The failure to comply with the FSAR

requirements was identified as a deviation (498/8741-01; 499/8741-01).

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. As immediate corrective action, HL&P Maintenance Manager issued

instructions to scope the problem, revise all applicable PMs and MWRs

prior to their performance, and prohibit the use of any applicable PMs &

MWRs issued to date until their review and revision is. complete. As

preventative action, additional retraining was to be performed for the  ;

personnel involved. In addition, in that above deviation deals with an

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operations phase problems, HL&P issued a memo to NRC (ST-HL-2293) dealing

with the construction phase. .This memo described the duel levels of

quality used in the construction phase of design, procurement, and

installation of the fire protection system and the logic rules used to

establish the different quality levels. The NRC has accepted this j

position statement. i

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The same revisions of December 1986 also added that PMs and MWRs on

environmentally qualified (EQ) equipment be identified on their respective

forms. A Special EQ Masterfile listing and Special EQ Maintenance book

were found which identify any EQ-related requirements for equipment. To (

date, some 1850 I&C PMs have been drafted and require rereview to meet  ;

this requirement. Only one of these PMs was -issued; however, it is not yet '

implemented.

A sample of records of 10 PM activities were reviewed by the NRC 4

inspector. Most PM activities were found to be performed with procedures j

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cross-referenced on the PM check sheet. The exceptions were inspection of

cleanliness of electrical cabinets which had the instructions documented .

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on the PM check sheet itself. PM check sheets referenced procedures

including revision status. The program procedure requires the latest

revision to be used. Only the latest revisions were issued by the

document control center as working copies. Based on the sample of PM

activities review, the latest revision was indeed used even when the PM

check sheet may have been referenced in an earlier revision.

In review of the above sample, it was found by the NRC inspector that

procedure changes are implemented by Field Change Requests (FCRs) as .

documented in Procedure No. OPGP03-ZA-0002. A review was performed by the

NRC inspector of PM procedures in ZI series. Six procedures were found to

have FCRs issued against them. Further review b

established that one procedure (0PMP08-ZI-0001) y the

had an FCR NRC

against it inspector ,

However, before the j

which expired and had been replaced by another FCR.

issuance of the replacement FCR, the document control center had (

issued working copies of the procedure. In addition, three other j

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procedures (23, 28, and 33) were found where the FCRs had expired, no

replacement FCRs had been issued, and working copies of the procedure had

been issued subsequently by document control. The nature of the changes

was reviewed by the NRC inspector with HL&P personnel and the changes were

found to be administrative and enhancing in character, such as the

addition of steps stating "if required." Although the changes were not

incorporated, this did comply with the procedure change methods of HL&P

program. FCRs are now tracked after PORC review and automatically added to

a new revised procedure.

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4. Exit Interview

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The NRC inspector met with Messrs. J. E. Geiger and W. H. Kinsey on

July 1,1987, and, the licensee personnel denoted in paragraph 1. At the

meeting, the scope and findings of the inspection were summarized.

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