ML20245E900

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Insp Repts 50-498/89-02 & 50-499/89-02 on 890101-31. Violations Noted.Major Areas Inspected:Plant Status,Esf Sys Walkdown,Monthly Maint & Surveillance Observation & Operational Safety Verififcation
ML20245E900
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/19/1989
From: Holler E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245E859 List:
References
50-498-89-02, 50-498-89-2, 50-499-89-02, 50-499-89-2, NUDOCS 8905020178
Download: ML20245E900 (15)


See also: IR 05000498/1989002

Text

{{#Wiki_filter:- ._ . _ _ . p ,4 / / < , v, c ,, < [[[ jI ' + . , , [:h,4<#4 f i ' s l - . 'i -APPENDIX B . , , ',f,M' U.S.lNUCLEAR REGULATORY ISSION ' ~ REGION IV. > , 4 .l . ,(NRCInspection. Report:- '50 498/89 02 .0perating License: NPF-76 - - A . 50-499/89-02 NPF-78 ' ' Dockets: iS0-498 t '"; 50-499 . ' Licensee:.. Houston Lighting &' Power Company (HL&P) P.O. Box 1700 Houston,' Texas 77001 L '

Facility Name: LSouth-Tex'as Project (STP), Units-1 and 2

. Inspection-At: STP, Matagorda County. Texas A . Inspection Conducted: January l'-31; 1989 , Inspectors: J. . E..' Bess, Senior . Resident Inspector.. Unit 1, Project ' Section D, Division of Reactor Projects ~ J. I. Tapia, Senior Resident Inspector, Unit 2,. Project . L . Section D, Division of Reactor Projects R. J. Evans, Resident' Inspector, Unit-1, Project. - Section D, Division of Reactor Projects D. M. Hunnicutt, Senior Project Engineer, Project Section D, Division of Reactor Projects 1 Approved: /f ' E. J./ Holler, Chief, Project Section D Date Division of Reactor Projects Inspection Sununary ' Inspection Conducted January 1-31, 1989 (Report 50-498/89-02) , Areas. Inspected: Routine, unannounced inspectien of plant status, previously identified inspection findings, engineered safety feature system walkdown, monthly maintenance observations, monthly surveillance' observations, and , operational-safety. verification. , .v 8905020178 890425 , PDR ADOCK 05000498 L Q PDC .;. , , ? __.__mu_____ _ _ _ _ _ _ _ _ m __ __ _a.___...m.

577^ ' L , , } . . - ' - 9s . - -2- pf' 4 , ' Results:: There were numerous' discrepancies pertaining to procedural nomenclatures and' equipment labeling. These concerns were identified to the licensee for. inclusion in the licensee's plant operation procedure program ce =(see paragraphs'4, 5, and 6). Weaknesses were noted in housekeeping practices. not.being followed in the control room (see paragraph 7). s Within the areasLinspected, no violations were' identified.- -Inspection Conducted January 1-31, 1989 (Report 50-499/89-02) s Areas Inspected:-- Routine, unannounced inspection of plant status, previously- ' 1 dent 1 fled Inspection; findings, . control room heating, ventilation, and air . conditioning, and startup procedure review. , Results: ~Within the areas inspected..one violation of NRC requirements was g identified'(failure to follow an approved procedure which requires independent verification'of safety, system restoration, paragraph 8). It was noted that the cause 'of this violation-resulted from'the unfamiliarity of Nuclear Plant Operations-Department with procedures writing requirements of the test director - Efor' the fire' protection program. The licensee effectively completed cold precritical testing and has achieved Mode 5. . The NRC inspector monitored the licensee's startup activities which continue:to proceed on schedule and cindicate a planned program that reflects good management attention. - , k g' I 4 l .! -l l - _ _ __ _ _ _ __ _-_____ _____.

. _ _ _ u g .} i; .

< . . . .. s. -3- 7 D' TAILS E .l.- Persons Contacted

  • W..P.' Evans,. Licensing Engineer
  • J. T. Westermeier, Project Manager
  • W. H.:Kinsey, Plant Manager

..

*S. L. Rosen, General Manager, Operations Support

'

  • M. R. Wisenburg, Plant Superintendent, Unit 1-
  • H.'H.-Johnson, Operations Manager, Unit 1

. Y. A. -Simonis, Plant Operations Support Manager

  • A. C. McIntyre, Manager, Support Engineer

'

  • D. 'A. _Leazar, . Reactor Support Manager
  • M. H. Carnley I&C Manager-
  • J. L. Lewis, Maintenance I&C Technical Support

' *J. E. . Geiger, General Manager, Nuclear Assurance

  • W. L.cMutz, IPS Manager
  • W. J. Jump, Maintenance Manager
  • J. R. Lovell,: Technical Services Manager

,~ Bechtel

  • L. W; Hurst, Project Manager

~ In addition to 'the above, the NRC insp(AE), constructor, and other- ectors also held discussions with various licensee, architect engineer contractor personnel during this inspection.

  • Denotes those individuals attending the exit interview conducted on

February 2,1989. '2. Plant Status At approximately 1:17 pm. on January 3,1989, with STP, Unit 1, at 100 percent power, a reactor trip occurred on over temperature / delta temperature in two of four reactor loops. A failure in the main turbine generator' electro-hydraulic control (EHC) system which closed the turbine generator. valves appears to have been the initiating event. Further investigation by the licensee indicated that the most probable cause of the EHC system failure was due to improperly crimped lugs on a wire which supplied power to several frames for printed circuit cards in the EHC cabinet. The licensee is continuing to investigate this event. The licensee will report this incident in greater detail in Licensee Event Report (lex)89-001. !> -On January 20, 1989, at approximately 11:20 a.m., the STP, Unit 1, main turbine was manually tripped from 100 percent power. The reactor operators decided to manually trip the main turbine when the control room . received a generator high temperature alarm, generator breaker trouble alarm, generator bearing high temperature alarm, and a fire alann, _: - _ _ _ _ - - _ ._ _ _ ___

) . . ,. . l -4- , associated with the generator. The reactor trip was the turbine being tripped with reactor power above 50 percent. There were indications that a fire had occurred on the No. 9 generator bearing. The licensee declared a Notification of an Unusual Event (N0VE) to monitor the generator conditions. The plant was stabilized in Mode 5 (cold shutdown). The licensee is investigating the cause of the main generator fire. The licensee will report this incident in greater detail in LER 89-005. On January 21, 1989, at approximately 11:27 p.m., STP, Unit 1, while in Mode 5 (cold shutdown), exp(erienced a loss of power to the "A" train j engineered safety feature ESF) bus. The loss of power to the "A" bus appeared to have been caused by a personnel error. While bleeding down the air receiver of the main generator circuit breaker, an operator accidentally pushed the " Test-Close" button for Pole "8" of the breaker. A differential current indication caused a transformer lockout to occur. The main transformer lockout caused a loss of the auxiliary transformer supplying the auxiliary bus cross-tie to the standby bus supplying power to the "A" ESF bus. The loss of power to the "A" ESF bus caused the auto start and load sequencing of the No.11 emergency diesel generator. The licensee will report this incident in greater detail in LER 89-006. At the end of the inspection period, STP, Unit 1, was in Mode 5 (cold shutdown). During this shutdown, licensee management decided that the bottom mounted instrumentation (BMI) tube work originally scheduled to start on February 24, 1989, would be completed prior to starting up Unit 1. STP, Unit 1, is scheduled to start up in early March 1989. During this inspection period, STP, Unit 2, experienced various cold precritical testing activities. The unit achieved Mode 5 on January 17, 1989. The unit remained in Mode 5 at the end of the inspection period. 3. Licensee Action on Previous Inspection Findings (92701) (Closed) Licensee identified Incident Response Change (IRC)-431: During Review of Solid State Protection System (SSPS) Design, the Licensee Discovered that SI can be Blocked Under Certain Conditions - Unit 2 ] On March 16, 1988, the licensee discovered a design error in Unit I which could cause a blockage of the safety injection (SI) actuation on each SI train (A,B, orc). The blockage could occur when the safeguards test cabinet master reset switch was operated and the reactor trip breakers were l open. The licensee issued a design char.ge to modify the Unit 1 SSPS ci rcuitry. LER 88-24 addressed this issue and was closed in NRC Inspection Report 50-498/88-55; 50-499/88-55. This design change was incorporated and installed in Unit 2. Installation of the design change in Unit 2 was verified. (Closed) Unresolved items (498/8852-02; 499/8852-02): Technical Adequacy of Emergency Operating Procedures (EOPs) The technical adequacy of Unit 2 E0Ps was previously reviewed by the NRC inspector. Because of the types of errors identified, the subject area

~ _ . . - ,. . t -5- 1 1 r was determined to be an unresolved item pending additional inspection. ' The NRC staff later conducted an E0P team inspection. The technical adequacy of both Unit 1 and 2 E0Ps was reviewed in depth by the NRC j inspection team. ! l The findings of the NRC team inspection on STP E0Ps were reported in NRC ] InspectionReport(IR) 50-498/88-68; 50-499/88-68. Therefore, previously ) identified Unresolved Item 498/8852-02; 499/8852-07 is considered closed. (Closed)UnresolvedItem(498/8873-02): Use and Distribution of f Calibration Deficiency Reports ! l During a previous inspection, the NRC inspector tried to determine whether ' Celebration Deficiency Reports were being used and distributed properly by the licensee. Previously, during the performance of routine preventive maintenance nn a transmitter, the technician failed to complete a Calibration beficiency Report in a timely manner, as required by two i procedures. S'ince the incident occurred, the licensee revised Procedure OPGP03-ZM-0016, " Installed Instrumentation Calibration Verification Program," Revision 1, to delete the Calibration Deficiency Report form. Per Step 4.4 of Procedere OPGP03-ZH-0016, a station problem report would be generated if an out-of-tolerance condition was found. To ensure that technicians comply with the requirements of Procedure OPGP03-ZM-0016, a step reminding the technician was added to each applicable maintenance procedure. Also, a signoff blank was added to each associated calibration data package. Unreselved Item 498/8873-02 is considered closed. 4. Eaginee ed Safety Feature (ESF) System Walkdown - Unit 1 (71710) The NRC inspector conducted walkdowns on Train "A" of the Essential Chilled Water (4W) system. The walkdowns were performed to independently verify the status of this ESF system. A review of the system was performed to confirm that the licensee's system operating procedure matched plant drawings and the as-built configuration. Equipment condition, valve positions, breaker positions, housekeeping, labeling, instrument calibration history, and operability of essential support systems were observed. A review of Procedure IP0P02-CH-0001, " Essential Chilled Water System," Revision 5, was performed, including a comparison of the procedure to the ! current system piping and instrument diagrams. The procedure was also ) compared to as-built conditions during a plant walkdown. W The following observations were presented to licensee management: The reference section, Section 2.0, failed to reference Technical l . Specification (TS) 3.7.14. _ - _ _ - - - _

. _ - _ - - - -_ __ . - _ = _ _ . _ .- - , . .. 1 - y.j - -6- j - , Step 5.3 provided' instructions to vent components and high points of ~ . Train "A." Two high point vents, 1-CH-V1679 and 1-CH-V1680,'were not identified in Step 5.3. Also in Step 5.3, Valve 1-CH-1581 should have been identified as an outlet valve, not an inlet valve. Step 5.7 provided instructions to START ECW Pump 11A without . identifying on which panel the control switch was located. Steps 8.1.4 and 8.1.5 directed the operator to manipulate or verify . proper position of two switches in the local chiller control panel. The procedure failed to mention a third switch, the " Temperature Control Point" switch. The licensee could not. clearly indicate whether this temperature control switch was to be adjusted by instrumentation and control technicians or verified properly set by operations personnel. This subject area will be tracked as an open item (498/8902-01) pending further review by the NRC inspector. The procedure was missing Step 8.1.3. In Section 8.1, Step 8.1.2 was . followed by'a Step 8.1.4. Section 8.0, " System Startup," did not provide instructions on how to . locally start a chiller. Labelling inconsistencies were observed in numerous places throughout . the procedure. For example, in the ECW Checklist, Train "A" -(IPOP02-CH-0001-1), the checklist identified Valve 1-NL-0162 as "N2 supply to A Pkg No.1 Tank Header Drain." The as-built label identified the valve as "ESS Chill Water Exp Tank 1A Supp Drain Valve."- In the Instrument Vent Checklist (1 POP 02-CH-0001-10), Instrument 1-CH-PI-9501 was identified as " Chilled Water Pump Discharge Pressure." The as-built label for 1-CH-PI-9501 was "ECHW Train A Supply Pump VAP004 Discrarge." ' Instrument Isolation Valves 1-CH-0010, 1-CH-0011, 1-CH-0012, . 1-CH-1317, 1-CH-1318, and 1-CH-1319 were not labelled locally. Additionally, these valves were not shown on the CH piping and instrument diagrams (P&ID). A licensee representative stated that Field Change Request (FCR) 89-0296 was written to delete the six valves from the procedure. " Pressure Indicators 1-CH-PI-9474,1-CH-PI-9474A,1-CH-PI-94748, . 1-CH-PI-9504,1-CH-PI-9504A, and 1-CH-PI-9504B were not labelled locally. These indicators are located on the local chiller control panel s. In the ECW Checklist Train "A" (IPOP02-CH-0001-1), Valve 1-CH-0609 was required to be in the Locked In Place, One Notch Open position. Per l . P&ID 3V119V10002 No.1, Revision 10, Valve 1-CH-0609 was required to ' be in the unlocked, full open position. Additionally, Valve 1-CH-1044 was identified as an inlet vent valve, but should have been identified as an outlet vent valve on the checklist. i_-_-__--.-.._...-.- _ . - - 1

_ _ _ _ _ _ _ . l l . . ! ' . ,, -7- On the ECW Electrical Checklist Train "A" (1 POP 02-CH-0001-4)', . Switch 2CB was identified as a control power toggle switch. This switch was an oil heater toggle switch. Additionally, Breaker DPA 135-7 was identified as the control power breaker for ,PV-6904 in the checklist. At distribution Panel DPA135, ' Breaker No. 7 was identified as SPARE. . . A typographical error was noted on local Distribution Panel DPA235 nameplate at breaker four position. The Panel No. ZLP623 was incorrectly identified as ZLP823 on the nameplate. Two. instrunent's (Al-CH-TSH-9435, and PSH-9533) were included in the . preventive maintenance program, but were not shown on the system P& ids.- Both instruments were associated with Train "A" Chiller VCH004. These discrepancies were identified to the licensee for inclusion in its plant operations procedure update program which the licensee has undertaken to assure the technical and editorial adequacy of procedures. In conclusion all valves and power supplies were found to be in the correct position per the system operating procedure. Housekeeping was maintained and equipment condition was considered acceptable. None of the discrepancies 1dentified above were considered to be significant operability concerns. No violations or deviations were identified in this area of the inspection. 5. Monthly Maintenance Observations - Unit 1 (62703) Portions.ofselectedpreventivemaintenance(PM)activitieswereobserved to ascertain-whether the activities were conducted in accordance with ~ approved procedures. The activities included: PM IC-1-CH-86009700, "ECHW Train B Chiller VCH005 Evaporator . Differential Pressure Switch Calibration," Revision 1H OPMP08-ZI-0009, " Pressure and Differential Pressure Switch . Calibration," Revision 3 PM IC-1-JW-86008520, " Diesel Generator No.12 Jacket Water Return .. Temperature Calibration," Revision 1A IPMP08-JW-5512, " Diesel Generator No.12 Jacket Water Return . Temperature Calibration (T-5512)," Revision 0 A review of the procedures and the completed data packages was performed. Additionally, the performance of :he procedures by licensee personnel was j observed. Items noted during the review and observation of IPMP08-JW-5512 ' fneluded: 1 1 j E___________________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ ____j

g- m- - . -- , d y + ": g 9 4 h [. b ~ p - -8- , 3 . ' (1, 3 ~~ In IPMP08-JW-5512, several labelling inconsistencies between as-found h ' . .. 1abels and procedure descriptions.were noted. For example, in Step 5.1.a, Panel.1-CP003 was incorrectly called ZCP-003. In < L . Step 7.4.1. Terminal Strip TB-12 was labelled 02-12 in the field. In I

~ Step 7.4.3, Card B02-0331 was labelled C2-0331 in the field. ' 3* .s . Step 7.4.6.7 required the technician to perform a zero adjustment .. ,' without' stating la change in test Jacks'was required to perform the-

.steo. .The technician had to change test jacks from BRIDGE CURRENT' l (Step 7.4.6.6) to OUTPUT /SIG COM to perform Step 7.4.6.7. No safety concern existed because this step was nonsafety related. , Instrument No.;TY-5512 was incorrectly. called TT-5512 in both the - - .. IPMP08-JW-5512 calibration data package and PM IC-1-JW-86008520 tag . ' number block. An. error in the instrument output indication tolerance was observed . in the IPMP08-JW-5512-1. calibration data package. The tolerance

applies to nonsafety-related Instrument N1JW-TI-5512A, the Diesel Generator (DG) 12 jacket water return temperature _ indicator. The plant instrument scaling manual . requires a tolerance of'*3'F. The calibration-data package instrument: tolerance was 3.75 F, which was .less conservative. The recorded data was observed to be~within 13*F of the required values.. Meter N1JW-TI-5512A, located on 1-CP003, was ob' served to be unusually . dusty on the interior of the meter. Although the dust did not impair the operator when reading the meter, it should have been cleaned to prevent possible failure. Items 'noted during the review and observation'of OPMP08-ZI-0009 and '" IC-1-ru-86009700 included: Step 7.3 of OPMP08-ZI-0009 references a' Calibration Deficiency Report . form and Procedure OPGP03-ZM-0016, Installed Plant Instrumentation. 4" ' . Calibration Verification Program. The latest revision of k' OPGP03-ZM-0016, Revision 1, deleted the Calibration Deficiency Report , form. Step 7.5.19 states, ". . . reconnect sensing line(s) to the switch." . This step should have been a signoff step similar to landitg leads, to indicate the instrument was properly reconnected to the permanent plant tubing. Step 7.6.11, added by FCR 89-0060, was added to the wrong page of the . calibration data package. IC-1-CH-86009700, Step 2.01, and the chiller panel electrical schematic drawing, indicates the NO FLOW light at the local chiller . 4 V

-- . . . -9- panel is red in color. The as-found lens cover for the NO FLOW light was green. The wrong colored lens cover was installed on the NO FLOW light. During the review of Procedure OPMP08-ZI-0009 calibration data package, it was observed that the data package did nct have Field Change l Notice (FCN) 89-0060 incorporated into the procedure. The FCN effective date was January 13, 1989, while the proceuure was performed January 20, 1989. Further review into this area identified several potential weaknesses. The weaknesses included FCN distribution and incorporation into working copies of procedures. The control, distribution, and incorporation of changes to procedures are governed by several documents, including Procedures RMSP 2.27, " Control and Distribution of STP Procedures and Manuals" (Revision 6); OPGP03-ZA-0002, " Plant Procedures" (Revision 16); and OPGP03-ZO-0007, " Conduct of Maintenance" (Revision 5). Three errors apparently were performed by licensee personnel: The effective date of the FCN was January 13,1989(Friday). All personnel who were issued working copies of Procedure OPMP08-ZI-0009 were not notified of the changes until January 16,1989(Monday). Procedare RMSP 2.27, Step 6.6.5, requires I work day (24 hours) notification to recipients of working copies that are amended. Additionally, clear instructions on how to notify the recipients of changes to working copies of procedures did not exist. Although notified by telephone of the changes to OPMP08-ZI-0009, the recipient (a preventive maintenance scheduler) of the working copy failed to incorporate the FCH into the procedure. The technician performing OPMP08-ZI-0009 f ailed to verify that the document was the most current one available, contrary to instructions 3 provided by Step 3.4.4 of OPGP03-ZO-0007, which states that, prior to l use, documentation shall be reviewed to ensure that work documents are current. FCN 89-0060 added a signoff step (7.6.11) to ensure the requirements of l OPGP03-ZM-0016 (Installed Plant Instrumentation Calibration Verification Program) were completed. Step 7.3 of OPMP08-ZI-0009 inforned the l

technician to follow OPGP03-ZM-0016 instructions if as-found data was found out of tolerance. Since the data was found in tolerar.;.e and Step 7.3 was previously included in the procedure, the failure to incorporate FCN 89-0060 into OPMP08-ZI-0009 did not result in a safety Concern. Licensee compliance with procedure requirements in the area of FCN l distribution and incorporation will be monitored by the NRC to determine if this incident was an isolated error or an indication of a programmatic weakness. l l - _ _ _ - __

_ _ . } , . p/' - - . . > . -10- No violations or deviations were identified in this area of the l inspection. 6. Monthly Surveillance Observations - Unit 1 (61726) i An in'spection of licensee surveillance activities was performed to ascertain whether the surveillance of safety significant systems and .) components were being conducted in accordance with TS and other requirements. The following surveillance tests were observed and ! reviewed: ' .1 PSP 02-RC-0438, "RCS Flow Loop 3 Set 2 ACOT (F-0438)," Revision 3 . 1 PSP 06-PX-0002, "4.16kv Class IE Undervoltage Relay Channel . Calibration /TADOT - Channel 2," Revision 1 The NRC inspector verified' that testing was performed using approved procedures, test data was within acceptance criteria limits, and testing was performed within the frequency of TS requirements. Spccific items noted during the review and observation of Procedure 1 PSP 02-RC-0438 included: Three TS sections referenced in the procedure (TS 3.3.2, Table 3.3-3, . Item 5.d; TS 3.3.2, Table 3.3-4 Item 5.d; and TS 4.3.2.1, Table 4.3-2, Item 5.d)havebeendeleted. These sections were listed in Steps 1.1, 6.1, and 10.4 and in the ACOT data package cover sheet (the delete TS sections also changed the required MODES from 1, 2, and 3 to Mode 1). Several labeling inconsistencies were observed. For example, in . Step 7.4.4, the annunciator panel was identified as 1-21M-1, but was labeled 21M01 in the control room. In Step.7.4.8, the bistable status monitoring panel (BSMP) was identified as 1-05M-2, but was labeled SM02 in the control room (also BSMP SM05 was not labeled in the control room). In Step 7.4.6.a. the card was identified as . P2A-0835, but was labeled C2A-0835 in the field. A minor difference existed between the TS allowable value listed in . the ACOT data package and plant instrument scaling manual, Loop No. DIRC-F-0438, Revision 3. The allowable value in the scaling manual was 3.295 vdc, while the data package allowable was 3.296 vde, a more conservative value. No violations or deviations were identified in this area of the . inspection. 7. Operational Safety Verification - Unit 1 (71707) The purpose of this inspection was to ensure that the facility is being operated in conformance with NRC requirements and the TS. This inspection also included verifying that selected activities of the licensee's _ . _ _ - _ _ -___ __ _ ____

_ _ / , . . , ' - . (, ! l -11- l i l radiological protection program were being implemented in conformance with requirements and procedures, and that the licensee was in compliance with its approved physical security plan. The NRC inspector inspected the control room on a daily basis and verified: ' Proper control room staffing was maintained. . Operators were adhering to approved procedures for ongoing . activities. Operability of reactor protective systems and engi,ieered safety . components was as required. Control room was free from distractions such as nonwork-related . reading materials. The NRC inspector toured various areas of the plant to observe work in progress. Posting of Radiation Work Permits (RWPs), the proper use of personnel dosimetry, and the correct methods for frisking when exiting the radiation protected area were observed. The NRC inspector verified that the licensee's security program was being implemented in accordance with its security plan. The NRC inspector observed that packages and personnel were properly checked prior to entry into the protected areas (PA), illumination in the PA was adequate to observe all areas during hours of darkness, and personnel inside the PA had proper identification badges. During several inspections of the control room, the NRC inspector noticed that the area identified as "at-the-control" area often became cluttered with various pieces of test equipment such as pressure indicators and test , gauges. The NRC inspector noticed that the tendency for test equipment { ' not in use to accumulate inside the "at-the-control area" was more prevalent during plant evolutions such as system or train outages. The NRC inspector brought this concern to the attention of the shift supervisors and informed them that good housekeeping practices were not being implemented. Materials such as test equipment not in use should be properly stored. This concern is further amplified in Plant Procedure OPGP03-ZO-0004, Revision 10, Section 4.6.5, which states, in part, that good housekeeping practices shall be followed in the control room by storing materials and dccuments not in use in their designated location. The shift supervisors informed the NRC inspector that the area identified as "at the controls" would have all equipment, materials, and documents stored in a designated location. Subsequent inspections of the control room by the NRC inspector indicated that test equipment put in use was being stored outside of the area identified as "at the controls." No violations or deviations were identified in this area of the inspection. j

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _____ \\. . . j - . - .. l- 1 -12- 1 l 8. . Control Room Heating, Ventilation, and Air Conditioning (HVAC) - Unit 2 (90501) On January 7,1989, the licensee discovered that the Unit 2 "C" train control room emergency ventilation system had been inoperable since December 29, 1988. The "C" train was inoperable because of plastic placed over the intake of "C" train makeup fan in connection with testing of a

Halon fire suppression system in a relay room. Subsequent investigation of why the plastic was not removed after testing of the fire suppression system disclosed that the station procedure utilized to conduct the Halon test (No. OTEP03-FP-0006, Revision 0, " Relay Room Halon Concentration Test") was deficient in that it did not require independent verification of the removal of the plastic. The signoff for system restoration was performed by the test director based on conversations he had with technicians involved in performing the test. Station Procedure OPGP03-ZA-0039, Revision 8, " Plant Procedures Writer's Guide," requires independent verification of restoration of any alteration to a safety system. This was not required in the Halon test procedure and, therefore, is an apparent violation (499/8902-01). TS 3.7.7 requires placing the control room in recirculation when an emergency ventilation train is inoperable for more than 7 days. Because this was not accomplished, the licensee issued LER 89-002, which discusses the event causes and corrective actions. 9. Startup Procedure Review - Unit 2 (72300) , An inspection was conducted of selected startup test procedures to determine their technical and administrative adequacy. The following attributes were specifically addressed: Management approval is indicated. . Procedure format is consistent with ANSI N18.7 and Regulatory . Guide 1.68. Test objectives are clearly stated. . Pertinent prerequisites are identified, e.g.: . a. Required plant systems are specified. b. Proper facility procedures are specified. I Completion of calibration checks, limit switch settings and c. protective device settings are included where applicable, d. Special supplies and test equipment are specified. l _ _ _ _ _ _

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.- , , -1S-- , -, , . f ~ Initial test conditions are specifie'd, e.g.:- ~ . 'a.. Valve lineups. < b. . El'ectrical power and control requirements. c. Temporary installations (instrumentation, electrical, and !

piping).

, d. . Temperatures, pressures, flows. e. . Water chemistry. The procedure includes a section listing references to appropriate . FSAR sections, Technical Specifications, drawings, specifications, codes, and other requirements. ,. Step-by-step instructions for the performance of the procedure are . complete to the extent necessary to ensure that test objectives.are met. Spaces'are provided for initialing that all items, including . prerequisites, are verified.as having been performed. l' Provision is made for recording details of the conduct of the test, . ,

including observed deficiencies, their resolution, and retest.

Proceduce requires that temporary connections, disconnections, or . jumpers be restored to normal. Procedure provides for. identification of personnel conducting the . testing and evaluating the' test data. Procedure provides for quality control verification of critical steps- . .or parameters. The procedure as issued is consistent with the test description . . provided in the Final Safety Analysis Report (FSAR). Special precautions for personnel and equipment safety are specified. .. ! Detailed instructions specify testing over the full operating range . and under the maximum anticipated load change of the system / component. Provision is made for the data taker to indicate the acceptability of . the data. . . V \\ ;.

- , . . , , . . . -14- l The specific procedures reviewed were the following: Station Procedure 2 PEP 04-ZL-0025, Revision 0, " Control Rod Drive . Mechanism Timing Test" Station Procedure 2 PEPO 4-ZL-0052, Revision 0, " Pressurizer Spray and . Heater Capability" Station Procedure 2 PEPO 4-ZL-0061, Revision 0, "Incore Moveable . Detector System Functional Test (H0T)" ! The procedures indicated consistent evidence of prior planning and the steps for the control of activities were well stated and explicit. No violations or deviations were identified in this area of the inspection. 10. Preoperational Test Witnessing (70302) The NRC inspector witnessed the licensee's conduct of the rapid refueling demonstration. This rapid refueling demonstration involved lifting the , integrated reactor head package while controlling the water level in the ! reactor cavity. During the filling of the reactor refueling cavity prior to the lifting of the head, leaks were identified in the cavity liner leak chase channels. The licensee suspended the demonstration and initiated a systematic investigation to identify the source of the water coming into the leak chase channels. After several fillings and emptyings of the reactor refueling cavity, the source of the leak was identified as being the reactor nozzle inservice inspection (ISI) access manway cover plates. The licensee then conducted extensive engineering reviews to define the appropriate corrective actions. The results of these analyses were a determination that ISI access existed underneath the fuel pool floor and a modification that replaced the leaking bolted cover plates with seal welded cover plates. The corrective action was effective and the . engineering evaluation was technically adequate. The NRC inspector also witnessed portions of the Incore instrumentation and control rod testing, the filling and venting of the reactor coolant , system, seal changeout on the "A" residual heat removal (RHR) pump, the l start of the "A" Reactor Coolant Pump No. I seal replacement, and the 3 i inspections conducted on the emergency diesel generator rocker arms. The NRC inspector noted that all activities witnessed were conducted in accordance with approved procedures which contained adequate instructions to provide an understanding of the work required and adherence to detail. ( 1 The quality of licensee's program to assure prior planning and control of activities was evidenced by the absence of errors or events attributable to , causes under the licensee's control. j J 11. Exit Interview The NRC inspectors met with licensee representatives (denoted in j paragraph 1) on February 2,1989. The NRC inspectors summarized the scope I l . m__._ _ _ _ _ . _ _ . ._ _ . -

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and findings of the inspection. The licensee did not' identify as

I ' . proprietary any of the information provided to, or reviewed by, the NRC inspectors. - s L- ., ' x (- 5, . T 1 i ' , ,. . . l -m--.-. _ . . . . _ _ . - - _ . - . - - - - - - _ - . - _ - - - - - _ - _ . - . _ _ . _ -- __. -_ . _ - _ _ _ _ _ . _ - _ - - _ _ . - . _ . _ _- _ -. -- .- __.- _ - - - - - - }}