IR 05000498/1996024

Insp Repts 50-498/96-24 & 50-499/96-24 on 961021-26 & 970106-16.No Violations Identified.Major Areas Inspected: Engineering

ML20135F978
Person / Time
Site:	South Texas
Issue date:	04/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135F977	List: IR 05000498/1996024 ML20135F974
References
50-498-96-24, 50-499-96-24, NUDOCS 9704040056
Download: ML20135F978 (29)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION  ;

REGION IV

Docket No ;50-499 License Nos.: NPF-76; NPF-80 Report No.: 50-498/96-24; 50-499/96-24 Licensee: Houston Lighting & Power Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas Dates: October 21-26,1996, and January 6-16,1997 Inspectors: T. Stetka, Team Leader M. Murphy, Reactor Inspector (October 21-26,1996)

W. Wagner, Reactor inspector (January 6-10,1997)

Approved By: C. VanDenburgh, Chief, Engineering Branch .

Division of Reactor Safety .

Attachment: Supplemental Information

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PDR ADOCK 05000490 G PDR

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l SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/96-24;50-499/96-24 This inspection evaluated the licensee's self-assessment effort that was performed as an alternative to an NRC engineering team inspectio Enaineerina ,

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• The licensee's self-assessment team was composed of well-qualified individuals, who were sufficiently independent and objective. The team was capable of  !

performing good assessments (Section E1.2). j

• The scope and depth of the engineering self-ass 3ssment team was sufficient to satisfy the requirements of NRC Inspection Procedure 37550 (Section E1.3).

• The licensee's engineering self-assessment team concluded, overall, that South Texas Project Electric Generating Station engineering was meeting program requirements. The team noted the following strengths in the engineering areas reviewed (Section E1.4):

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Engineering support to operations and maintenance departments, especially for emergent work, was excellen 'The engineering management team was sensitive to plant need Communications with operations and maintenance personnel was excellen Engineering support contributed to outage planning, scheduling, and implementatio The temporary modification program was characterized as having high quality products that were effectively implemented and manage * The licensee's engineering self-assessment team noted the following weaknesses in the engineering areas reviewed (Section E1.4):

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System engineering walkdowns could be enhanced by using the assinance of operations and maintenance personne The system engineering walkdown reports and system health reports were l not being used by engineering management to provide a focus on system material condition and engineering recommendation System engineers need to be aware of the potential impact of system l problems on operating personne i iii I

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System engineering health reports should be issued more frequently to improve their effectivenes Setpoint index values were found to be incorrect, electrical setpoint databases were found to be inaccurate and to have incomplete setpoint basis references, and the instrument setpoint document was found to have overly restrictive tolerance Management's expectations regarding the use of the design basis documents were unclea Several design basis documents were found to have several unincorporated amendments and did not reflect current plant design or configuratio The modification process lacked guidance and did not meet management expectations with regard to level of detail in design packages, the criteria for minor changes, and work package closur * The findings identified by the self-assessment team were generally representative of engineering's strengths and weaknesses. These findings were consistent with those observed by the NRC inspectors (Section E1.4).

• While the self-assessment team was effective in identifying adve se conditions, the team f ailed to provide an overall assessment to ensure that adequate corrective actions were implemented for three adverse conditions they identified. This failure reduced the effectiveness of the engineering self assessment (Section E1.5).

• While the self-assessment team identified specific design control,10 CFR 50.71 compliance and procedure adherence issues, the team did not assess the overall implications of these findings in their self-assessment report (Section E1.5).

• The self-assessment team was very effective at identifying problems with plant calculations and appropriate corrective actions were taken (Section E1.5).

• The engineering backlog was properly managed and had a steady trend (Section E1.5).

• The system engineers were found to be knowledgeable of their systems, to have good communications with other plant disciplines, and to be readily identifying plant problems. The NRC inspector's findings regarding system engineers were consistent with the self-assessment team's findings (Section E1.5).

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Report Details lik Enaineerina E1 Engineering Self Assessment

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E1.1 Introduction An NRC Region IV team inspection was planned to accomplish the core inspection program requirements of NRC Inspection Procedure 37550, " Engineering," in October 1996, at the South Texas Electric Generating Station. In a letter dated

August 15,1996, Houston Lighting and Power Company, the licensee, proposed to perform a self assessment of South Texas Electric Generating Station engineering activities and programs in lieu of the planned NRC engineering team inspection. The l licensee included its engineering self-assessment plan as an attachment to the j letter. The plan provided the details regarding the schedule, objectives, scope, I methodology, and team qualifications for the self assessmen !

In a letter dated August 22,1996, the NRC informed the licensee that their request

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was reviewed in accordance with the guidelines contained in NRC Inspection Procedure 40501, " Licensee Self Assessments Related to Team inspections," and J accepted the proposed timing, scope of effort, and the credentials and experience I of the assessment team. The option of permitting licensees to conduct a self (

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assessment in lieu of an NRC inspection was an NRC program aimed at minimizing l

- regulatory impact and utilizing NRC resources more efficiently. Consequently, the I

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NRC informed the licensee that it planned to reduce the level of inspection effort planned for inspection Procedures 37550, " Engineering," at the South Texas Electric Generating Station. The NRC further informed the licensee that it planned i to perform an inspection of the self-assessment effort in accordance with NRC I Inspection Procedure 4050 ,

The licensee performed an engineering self assessment at the South Texas Electric Generating Station on October 14-24,1996. The results of the self-assessment

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were contained in a self assessment report that was submitted to the NRC on '

December 12,1996. The NRC inspectors monitored the performance of the engineering self assessment on October 21 25,1996, reviewed the self-assessment results, and independently inspected the areas assessed by the licensee on January 6-10,1997. The NRC inspectors continued the review of documents in i office. The purpose of the NRC reviews and inspections was to determine the quality and results of the licensee's self assessment. Following a completion of these reviews, an exit meeting was held with the licensee on January 16,199 ,

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E1.2 Self-Assessment Team Qualifications. Obiectivitv. and independence a. ' Inspection Scope (40501)

The purpose of this inspection was to determine the qualifications, objectivity, and independence of the licensee's self-assessment team in accordance with NRC Inspection Procedure 40501, " Licensee Self Assessments Related to. Team inspections." The inspectors determined the qualifications, objectivity, and independence of the licensee's engineering self-assessment team and individual team members by performing the following:

• The NRC inspectors reviewed the licensee's engineering self-assessment plan prior to, and during, the onsite inspectio * The NRC inspectors interviewed selected team member q i

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• The NRC inspectors accompanied and observed selected team members during their assessment activities. At the time of the onsite inspection, the ongoing team assessment activities were predominantly interviews of licensee personnel and reviews of engineering work product * The NRC inspectors observed daily team meetings.

I Observations and Findinas The NRC inspectors found that the engineering self-assessment team consisted of 14 Houston Lighting and Power Company engineering personnel,1 design

!. engineering supervisor from the Diablo Canyon Nuclear Power Plant, and 1 engineering program supervisor from the Palo Verde Nuclear Generating Statio The inspectors determined that the team was composed of diverse and well- '

qualified members who were sufficiently objective and independent to allow i meaningful assessments. Specifically, the inspectors noted the following:

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l Eleven of the engineering team members had engineenng degrees. The major

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engineering disciplines of mechanical, electrical, civil, and nuclear i engineering were represented on the tearn. The other three team members  ;

l had over 19 years experience in the nuclear industry and two of these i

! members were licensed senior reactor operator ;

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• All team members had 9 or more years of industry experience in design, systems, or plant support engineering functions.

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• Team member assessment activities observed by the NRC inspectors were independent and self critical. Team meetings observed by the inspectors included critical discussions of team member observations.

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. Conclusion The NRC inspectors concluded that the team was composed of well-qualified individuals who were sufficiently independent and objective. The team was capa:*le of performing good assessment E13 Scope and Deoth of Self Assessment Inspection Scope (40501)

The NRC inspectors reviewed the scope and depth of the licensee's self assessment to determine if it was equivalent to thtve requirements specified in NRC Inspection Procedures 37550, " Engineering." The inspectors reviewed the self-assessment plan, observed in process assessment activities, interviewed licensee personnel, and reviewed the licensee's self-assessment repor Observations and Findinas Enaineerina Self Assessment The NRC inspectors determined that the licensee's engineering self assessment consisted of both a horizontal and a vertical review. The licensee chose to review the emergency chilled water system and the essential chilled water system, the Class 1E 125V dc power system, and the condensate system for the vertical review of engineering activities for those systems. The adequacy of engineering activities regarding design and configuration control, surveillance and testing, and identification and resolution of problems associated with those systems were l reviewe The licensee chose 11 engineering subject areas for the horizontal review of engineering activities. These areas included the following: l

• Customer support, l

• Emergent work support,

• Weekly maintenance schedule support,

• Permanent / temporary modifications,

• Walkdown/ system health reports,

• Configuration management,

• Engineering workload management,

• Use of industry and in-house operating experience,

• Preventative maintenance program,

• Maintenance rule, and

• Probabilistic risk assessment.

I j The team prepared a matrix of team assessment activities as compared to the inspection requirement attributes of NRC Inspection Procedure 37550. The NRC inspectors found that the licensee had addressed all portions of Inspection Procedure 3755 l l

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. Conclusion The NRC inspectors concluded that the scope and depth of the engineering self-assessment was sufficient to satisfy the requirements of NRC Inspection Procedure 3755 E1.4 Sianificant Self-Assessment Team Conclusions j Inspection Scope (40501)

The NRC inspectors reviewed the licensee's self-assessment report. The NRC inspectors discussed the results of the self assessrnent with licensee managers, the team leader, and team members. The inspectors summarized the licensee's conclusion Observations and Findinas Enaineerina Self Assessment j

' I The self-assessment team concluded, overall, that South Texas Project Electric Generating Station engineering was meeting program requirements.

The assessment team noted the following strengths in the engineering areas reviewed:

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• Engineering support of operations and maintenance, particularly for emergent work, was excellen * Engineering was responsive to plant need * Communications between plant operations and engineering was excellen * Engineering support contributed to successful outage planning, scheduling, and implementatio * The temporary modification program was characterized by high quality products that were effectively implemented and manage The assessment team noted the following weaknesses in the engineering areas

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I reviewed:

• The quality of system engineering walkdowns could be enhanced by having maintenance and operations personnel participate in the walkdowns and by increasing system engineer sensitivity to potential operator impact * System engineering walkdown reports should be used to provide management focus on system material condition .. .. _ _ _ _ . - .

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System engineering health reports could be improved by issuing the reports more frequently and by using the health reports as a method to provide increased management focus on system material conditions and engineering

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• Databases within the configuration management program had incorrect setpoint index values, inaccurate and incomplete setpoint references in the electrical setpoint databases, and restrictive tolerances in the instrument

setpoint document.

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Management expectations regarding the use of design bases documents as a j reference or source document were unclear.

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Some design basis documents did not reflect the current plant configuration

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The modification process needed guidance regarding the level of detailin

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4 Conclusions The NRC inspectors concluded that the findings identified by the self-assessment team were generally representative of engineering's strengths and weaknesses, i The inspectors also concluded that these findings were consistent with those i observed by the inspector E1.5 . Indeoendent NRC Insoection Insoection Scope (40501)

-The NRC inspectors observed licensee performance. of the self assessment and )

reviewed the detailed self-assessment plan implementation matrix, the self- j assessment team's field notes, the team's final report, and 35 associated condition reports to determine the status of the corrective actions for the identified conditions i and develop an understanding of the basis for the self-assessment team's conclusions. The NRC inspectors also walked down the technical support center and the balance-of-plant diesel generators to confirm the as-built configuration of the systems. The NRC inspectors interviewed self-assessment team members and ,

other cognizant licensee personnel. The inspectors also attended self-assessment team meeting I I

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- Observations and Findinas

The NRC inspectors generally agreed 1 the conclusions of the licensee's self- l'

assessment team. The inspectors cont,Jered the self-assessment team to be effective in conducting the assessment, in that, in-depth and critical reviews were l performed. The inspection activities, which resulted in a divergent or amplifying view, are described belo ,

l b.1 Use of the Corrective Action Proaram l

The executive summary of the assessment report stated that the conditions I identified during the assessment were addressed using the corrective action program, interviews with plant personnel and self-assessment team members indicated that these personnel were confident that the corrective action program would properly resolve the identified conditions. The NRC inspectors noted that condition reports written by the self-assessment team members were entered into the corrective action program; however, the self-assessment team did not perform any assessment to assure that the corrective actions properly addressed these deficient conditions. In addition, the NRC inspectors noted that any issues identified by the self-assessment team that had been previously identified in other I condition reports and already entered into the corrective action program, did not l receive an overall assessment to determine their impact on the facility. The NRC inspector's reviews identified several examples where this lack of an overall j assessment reduced team effectivenes ]

I (1) Failure to Assess the Adeauacy of Corrective Actions (a) Sizing of Molded-Case Circuit Breakers - The first example concerned an instance where the self-assessment team did not write a condition report, nor followup on an issued condition report. This condition involved the size of an installed molded-case circuit breaker that was not consistent with the breaker size identified in the setpoint inde Duiing the first week of the inspection, the NRC inspectors noted that team members identified this condition during a team meetin However, after reviewing the final self-assessment report, the NRC inspectors noted that this condition was not documented in the report. During interviews with the team leader during the second week of the inspection, the NRC inspectors were informed that this ,

finding was not included in the report because the finding was already l in the corrective action progra Further review by the NRC inspectors indicated that Condition Report 96-12772 was written when the condition was identified by maintenance personnel (which was prior to the self assessment). The ,

NRC inspector's review of this condition report indicated that the i corrective actions were not complete, in that, the corrective actions i only assured that the questionable circuit breaker was properly sized

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and did not verify that other similar circuit breakers were also properly sized. The NRC inspectors also noted that this condition existed since new construction and, even though was subjected to periodic surveillances, was not identified until the recent surveillanc Based on the NRC inspector's comments, the licensee initiated additional corrective actions. An investigation by the licensee I indicated that the affected circuit breaker was installed by a particular !

vendor during new construction and that this vendor failed to update the applicable bill of materials. A letter from this vendor confirmed the bill of materials problem and limited the number of affected circuit breakers to eight breakers. No similar problem was found with these breakers. In addition, the licensee planned to walkdown ten additional breakers to verify that this condition was limited to these vendor-specific circuit breaker While the NRC inspectors considered these licensee actions to be appropriate and responsive to the identified conditions, the inspectors considered this finding to be indicative of a lack of a proactive approach to a condition by engineering. In addition, the inspectors noted that the incomplete corrective actions were not identified by the self-assessment team. The NRC inspectors considered this to be an example where the lack of an assessment by the self-assessment team resulted in a condition not being fully addressed and inherent ,

engineering weaknesses identifie j (b) Design Basis Document inconsistencies - The second example ,

involved an instance where the self-assessment team identified inconsistencies between the design basis documents and the presen plant design and configuration. Condition Report 96-12688, written by the self-assessment team, identified that the chilled water heating, ventilation, and air conditioning system did not have local control as indicated in Section 2.A.1.1.5 of the design basis document. In addition, Condition Report 96-13013, also written by the self-assessment team, identified a number of findings affecting the design basis documents. These findings included:

• A significant difference in the application and interpretation of the design basis document;

• A lack of incorporation of all design changes in design basis documents; i

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• Design basis documents that had greater than 15 amendments posted against them, whereas the design basis document plan required the design basis document to be revised if the number of amendments exceeded 15 amendments (e.g., the main generator design basis document had 45 changes posted and was not revised);

• The use of a design basis document as a source document in Condition Report Engineering Evaluation 96-12546-1, which was inconsistent with management expectations regarding the use of design basis documents; and

• The present design basis document program plan, dated March 1990, did not reflect current management expectation In response to these findings, the licensee issued a revised Design Basis Documentation Program Plan on December 18,1996. The NRC inspectors reviewed this plan and discussed the design basis document process with licensee personnel. As the result of this review and discussions, the inspectors were informed that the licensee considers design basis documents to be "living" documents and, therefore, were maintained current. The licensee was also in the process of incorporating the design basis documents into a standard format (they were in different electronic formats). When each design basis document was placed into the standard format, all outstanding amendments were then incorporated. The inspectors were also informed that the licensee was considering expanding the scope of the design basis documents to include additional system The NRC inspectors noted that the revised plan did not appear to provide for verification that the design basis documents were consistent with the present plant design and configuration. Further discussions with licensee personnel indicated that the intent of the plan was to assure that such verifications were performed. Following these discussions, licensee personnel issued revised guidance to clarify that the intent of _the plan was to verify the accuracy of the design basis documents. The inspectors considered this to be another example where the lack of an assessment by the self-assessment team resulted in a condition not being fully addresse (c) Essential Chiller Insulation Degradation - The third example involved insulation on the essential chillers. The self-assessment team found that the insulation on Chiller 21 A was sagging due to water intrusion, which could cause corrosive effects. As the result of this finding, the self-assessment team issued Condition Report 96-12737. This condition report also identified that similar

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conditions had previously been documented on Chillers 21B and 21C in Condition Reports 96-3558 and 96-3559. The corrective actions for these previous conditions included repairing the damaged insulation on Chillers 218 and 21C, and only observing the condition on Chiller 21 The NRC inspectors noted that in identifying the new condition, the self-assessment team did not assess the adequacy of the corrective actions for the previous condition reports. The NRC inspectors considered these prior conditions to be examples where engineering l had not been effective in identifying a potential system degrading condition. The NRC inspectors concluded that the insulation failure l'

on Chiller 21 A could have been avoided if the recurrent nature of the insulation failure had been recognized and action initiated to replace I the insulation on Chiller 21 A. The NRC inspectors also noted that the self-assessment team did not identify this as an engineering weakness. The NRC inspectors considered this to be another example where the lack of an assessment by the self-assessment team resulted in a condition not being fully addressed and inherent engineering weaknesses identifie (2) Failure to Assess the Generic Imolications of Team Findinas (a) Design Control- While the self-assessment report did identify specific problems with the licensee's design control process, the report did not assess these issues and identify an overall design control problem indicated by the following example * Discrepancies Between the Design Basis Setpoint index and !

the Scaling Sheet - (Licensee Self-Assessment Condition '

Report 96-13152)- The self-assessment team's review of the i setpoint index discovered 50 of 450 safety-related setpoints, where the setpoint index did not match the scaling sheet. The licensee issued Action Number 96-13152-1 (a corrective action to Condition Report 96-13152) to perform an operability review. This action determined that the instruments installed in the plant were operable because they reflected the latest design change documents. The licensee also issued Action Number 96-13152-2 to develop an action plan to address the

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discrepancies between the setpoint index and the scaling sheet. Due to the self-assessment team's findings and followup actions, the NRC inspectors noted that the licensee expanded their sample size to 100 percent when the extent of this problem was realized. The NRC inspectors considered this to be a good example where the seh-assessment team assessed the condition which resulted in implementation and planning of thorough and complete licensee actions to resolve the proble .- .- ._- - _--- - . - ~ . - . - _. . - . - _

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. i a improper Drain Nipple Pipe Caps Installed on the Essential '

Chilled Water System -(Licensee Self-Assessment Condition Report 96-12729) - The self-assessment team's walkdown of the Unit 2 essential chilled water system identified that the drain nipples associated with Valves 2-CH-0592 and 2-CH 0908 had stainless steel pipe caps installed. This l

configuration was not consistent with the design criteria

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specified in Plant Procedure SLO 19PSOO4, "WA Specifications." Procedure 5LO19PSOO4 specified carbon-  :

steel, not stainless steel, as the pipe cap material. The stainless steel caps were replaced with the specified carbon steel caps by October 21,199 * Improper Washer Installed on the Essential Chilled Water System - (Licensee Self-Assessment Condition Report 96-12740)- The self-assessment team's walkdown of the Unit 2 essential chilled water system also identified that an insulation washer was installed backwards on the 6-inch flange connection to the Essential Chiller 21 A Return Line. The washer was removed and installed correctly by October 17, 199 * Inadequate Condition Report Engineering Evaluation 9511341-5 (Licensee Self-Assessment Condition Report 96-12814) - During the self-assessment team's review of Condition Report 95-11341 and the associated Condition Report Engineering Evaluation, the team identified that Calculation MC-5234 assumed a maximum peak pressure of 154 psi due to water hammer during a loss of nitrogen pressure on the Train C essential chilled water expansion tan The associated engineering evaluation f ailed to identify that the expansion tank has a design pressure of only 50 psi and that a overpressurization of the expansion tank could cause a trip of the essential chilled water pumps. While licensee investigation and documentation indicated that the calculation was incorrect and that the expansion tank was not impacted by such a water l hammer event, this was another example where design control !

was inadequate. On page 7 of the self-assessment team's I report, the team listed the condition report engineering evaluations that were reviewed. Based on this review, the team concluded that there were no problems with engineering evaluations. While the issue discussed above was identified through a team issued condition report and appropriate corrective actions were taken, the issue was not identified as an engineering evaluation problem. Instead the report stated

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that the engineering evaluations reviewed were thorough and had appropriate conclusion .

While the self-assessment team identified these issues as discrepancies and the licensee had taken or was taking appropriate corrective actions, the team did not identify these as overall design control problems. The NRC inspectors considered each of these to be examples of a lack of design control by engineering. While the pipe cap and the washer conditions involved installation activities by licensee trade personnel, the NRC inspectors considered the fact that engineering (e.g., through system walkdowns) failed to identify and initiate corrective actions for these conditions to be indicative of a lack of design control by engineering. While not identified as a overall problem by the self-assessment team, the licensee informed the NRC inspectors that they were taking actions to address the generic implications of these finding The licensee stated that they were reviewing their design control ,

process through their 10 CFR Part 50.59 and updated fin ;l safety analysis report steering committees. These committees are reviewing design conditions as they apply to the design basis, Tha licensee also stated that an additional self assessment of the setpoint document and index program was completed and that associated corrective actions were being implemented. The licensee also informed the inspectors that engineering managers were personally reviewing each condition report written by the self-assessment team to determine if ,

any generic implications existed. This review was expected to be completed by March 1997. The inspectors also noted that the licensee's condition review group was developing policies that addressed 10 CFR 50.59 and configuration management issue While the licensee did identify the specific conditions and was taking corrective actions to address the overall aspects of the conditions, the NRC inspectors concluded that these findings represented a condition that was contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," and was considered to be a violation. This licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-498/499/9624-01).

(b) Updated Final Safety Analysis Report Discrepancies - The self-assessment report identified two examples where the Updated Final Safety Analysis Report was not consistent with plant procedure ,

These examples were documented in the following self-assessment team initiated condition reports:

• Incorrect 125V DC Battery Charger Lineups (Licensee Self-Assessment Condition Report 96-12998) - The self- 1 assessment team identified that Updated Final Safety Analysis Report, Sections 8.3.2.1.1 and 10A.2.4, stated that both I i

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l 125V de battery buses were energized by both battery chargers. This was inconsistent with actual plant operation, which has each battery bus supplied by a single battery I charger. Licensee personnel stated that this was an apparent I discrepancy, in that, the Updated Final Safety Analysis Report i was not clear and subject to interpretation. Review of the i I documentation by the NRC inspectors confirmed that there was an interpretation problem. The licensee stated that they would revise the updated safety analysis report to remove the ambiguit *

Incorrect Question Answer Regarding Battery Charger Loads !

(Licensee Self-Assessment Condition Report 96-13003) - The

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self-assessment team identified that the Updated Final Safety '

Analysis Report, Question 430.37N, response was incorrect i l and did not fully answer the question. The question and answer involved whether the battery chargers were capable of supplying loads if they are not connected to the batteries. In i actuality, the battery chargers could supply loads even though they were not connected to the batteries.

l The NRC inspectors were informed that the licensee had an extensive

! updated final safety analysis review and assessment program

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underway. This program was approximately 67 percent complete and I was planned to be fully completed by the end of 1997. The NRC l

, inspectors reviewed this program and determined that the program l was thorough and effective and should correct any updated safety

! analysis discrepancies. The issue identified in Condition l l Report 96-13003 involved the question and answer section of the I i updated safety analysis report which had not yet been reviewed. The l inspectors concluded that the licensee's Updated Final Safety j Analysis Report updating program was very effective in assuring  ;

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Even though the licensee had an extensive and effective program  ;

underway to update the Updated Final Safety Analysis Report, the i self-assessment findings represented a condition that was contrary to

the requirements of 10 CFR Part 50.71 and was considered to be a violation. This licensee-identified and corrected minor violation is i

being treated as a noncited violation consistent with Section IV of the l l NRC Enforcement Policy (50-498/499/9624-02).

l (c) Procedure Adherence - The self-assessment team identified three l examples where plant procedures were not followed. These l examples were documented in self-assessment team initiated l condition reports.

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improper Process 4g of a Modification as a Trivial Change (Licensee Self-Assegment Condition Report 96-12921) The self-assessment team' identified that Modification 91-051, which added a refrigerarNcleanup kit to the safety-

, related essential chilled wa't system, was processed as a j trivial change. Procedure 0 05-ZA-0002, "10 CFR 50.59 Evaluations," states that trivial anges can only be used for nonsafety-related systems. Thbefore, processing Modification 91-051 as a trivial chanh was inconsistent with the requirements of Procedure OPGP05RA-0002. The licensee subsequently performed a 10 CFY 50.59 evaluation on this modification and determined that no ety review condition existe ,

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Failure to Determine Operability as Required by Prochdure (Licensee Self-Assessment Condition Report 96-12944. - The self-assessment team identified that previous Condition s Report 96-5203 that involved a hot spot on a fuse identifie\

during thermography had operability and reportability \

designated as " indeterminate." Procedure OPGP03-ZX-0002, \

" Condition Reporting Process," requires the operability and \

reportability questions to be answered as a "yes or "no." This condition was properly resolved by verifying that no operability or reportability condition existed and by counseling the person 3 involved. While the self-assessment team identified that this condition was inconsistent with the requirements of Procedure OPGP03-ZX-0002 and issued a condition report, the NRC inspectors noted that this condition was not documented in the self-assessment team's repor * Improper Classification of Plant Modifications (Licensee Self-Assessment Condition Report 96-13216)- The self-assessment team identified that some modifications (e.g., the installation of programmable logic controllers in the condensate polishing system) were incorrectly identified as " minor i changes." This designation was dependent on budget i considerations, in that, if a modification cost less than

$40,000, it was considered to be a minor change. Some modifications, which exceeded the $40,000 limit, were l performed as minor changes which was inconsistent with the i requirements of Procedure OPGPO4-ZA-0002, " Condition l Report Engineering Evaluation Program." The NRC inspectors noted that the review requirements were the same for minor j changes as for all other modifications. The licensee addressed this condition by forming a multi disciplinary team to evaluate l and review the finding I

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While the self-assessment team identified these issues as l discrepancies and the licensee had taken or was taking appropriate l corrective actions for the specific examples, the self assessment did '

not identify these issues as overall procedure adherence problem The NRC inspectors concluded that these findings constituted a violation of minor significance and is being treated as a noncited violation consistent with Section IV of the NRC Enforcement Policy I (50-498/499/9624-03).

(2) Independent NRC Inspection The NRC inspectors reviewed the following additional areas to assess the adequacy of the licensee's self assessment.

• Engineering Backlog - While the self-assessment team's report discussed engineering work load management, it did not provide an insight into the licensee's engineering backlog. As a result, the NRC inspectors conducted a review of the engineering backlo Since the licensee used their condition report process to address all activities at the facility, their backlog was based upon the open condition reports. In addition to providing a system to identify, track progress and correct deficient conditions, the condition reports also included design change packages, minor and ,

major modifications, temporary modifications, minor changes, I condition report engineering evaluations and any other engineering

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evaluations. Each condition report was subdivided into actions from which various department assignments were made so that the l condition would be resolved. Furthermore the condition report would be assigned an owner department that would be responsible for tracking the report to closure. As of the time of this inspection, the licensee's backlog of open condition reports that were assigned to engineering as the owner consisted of 1182 condition report This included 60 modifications,148 minor changes,81 design change packages (that involved paper changes), and 6 temporary modification \ To provide action priorities, the condition reports were assigned

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specific quality designations. The highest priority was for significant conditions adverse to quality and the lowest priority was for conditions that were not adverse to quality. The NRC inspectors noted that the 1187 condition report backlog contained ten items that were considered significant conditions adverse to quality, 49 conditions adverse to quality - station level, 235 conditions adverse to quality - department level, and 887 conditions that were not adverse to quality. Of these designations, only a significant condition adverse to quality could involve the safe operation of the plan .

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l The NRC inspectors reviewed the ten significant conditions adverse to '

quality. This review indicated that all ten were being processed for resolution, that the majority of the assigned actions were closed and that the remaining actions were on schedule for closure. The inspectors noted that the immediate concerns were addressed and considered the schedule for cornpletion of the remaining actions to be 1 appropriate. The inspectors reviewed the trend of this backlog and !

noted that it was steady indicating that the licensee was managing the existing backlog. Based upon this review, the NRC inspectors concluded that the backlog was being properly manage * System Walkdowns - The NRC inspectors conducted a walkdown of a l system that was not reviewed oy the self-assessment team to determine if the self-assessment team's conclusions based upon the systems reviewed by the team were consistent with conditions noted by the inspectors. The inspectors selected the balance-of-plant and technical support center diesel generators for a system walkdow j These components were selected because, while they were non- '

safety related, they were high on the facility's risk profile. The inspector's walkdown included a review of the Updated Final Safety ;

Analysis Report criteria, the system description, and all minor changes i installed on the system. As the result of this walkdown the {

inspectors determined that: I l

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This system did not have a design basis documen I i

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The system description was out-of-date. However, following discussions with licensee personnel, the NRC inspectors were l informed that the licensee did not intend to keep these system l descriptions current. The inspectors also noted, based on

! discussions with the system engineer, that the lack of an updated system description and a design basis document l placed a burden on engineers to determine design criteria. The system engineer further informed the inspectors that the lack of a design basis document did not prevent them from obtaining necessary information, in that, they could obtain necessary information from such documents as vendor information and plant drawings.

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The system engineer had a thorough understanding of the l system and was aware of planned or ongoing issues on the f system.

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Minor changes were proper and installed as designe .

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The NRC inspectors also noted, based on this very limited sample, good communication between the engineer and operations personnel and that the system engineer was encouraged to identify and document problems (via the condition reporting process). This finding was consistent with the self-assessment team's findings regarding operations suppor j i

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• Calculations - With the exception of Calculation MC-5234 discussed i previously, the NRC inspectors considered the self-assessment team's review of plant calculations to be very good. Based upon the NRC inspector's review, the inspectors concurred with the self-assessment team's findings and corrective actions for the identified condition The inspectcrs also noted that no operability issues were identified as ;

the result of the self-assessment team's finding * Temporary Modifications - The NRC inspectors conducted an independent review of the six open temporary modifications to determine if these modifications were installed in accordance with the licensee's temporary modification program. In addition, the inspectors walked down Temporary Modifications T1-96-11616-2 and T2-96-3958-2 (f or digital individual rod position indication on each j unit). The inspectors concluded that the number of ternporary I modifications was low and that the modifications were installed in accordance with the licensee's progra c. Conclusions j i

The NRC inspectors concluded that the self-assessment team was effective in i conducting the assessment and identifying adverse conditions. However, the NRC

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inspectors also concluded that the self-assessment failed to provide an overall assessment of the effectiveness of the corrective actions for their finding Although the self assessment identified specific design control,10 CFR 50.71 compliance, and procedure adherence issues, the NRC inspectors concluded that the lack of an assessment of these specific conditions resulted in a failure to identify the overall implications of these deficiencies. This lack of an overall assessment limited the effectiveness of the engineering self assessmen The NRC inspectors concluded that the self-assessment team was effective at identifying problems that involved plant calculations and that appropriate corrective actions were taken. The NRC inspectors considered the engineering backlog to be properly managed and to have a steady trend. The NRC inspector's findings regarding system engineers were consistent with the self-assessment team's findings. The inspectors found the system engineers to be knowledgeable of their systems, to have good communications with other plant disciplines and to readily identify plant problem l

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V. Management Meetings X1 Exit Meetipo Summarv

The NRC inspector presented the inspection results to members of licensee

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management at the conclusion of the inspection on January 16,1997. The

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licensee acknowledged the findings presente The team asked the licensee whether any materials examined during the inspection

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ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. Beers, Senior Consulting Engineer P. Bengel, System Engineer J. Carbone, Supervisor, instrumentation and Controls Design L. Casella, Supervisor, Technical Support Engineering T. Cloninger, Vice President, Nuclear Engineering M. Forsyth, Supervisor, Reliability Engineering J. Gruber, Assessment Team Leader E. Halpin, Manager, Mechanical / Civil Design W. Harrison, Supervising Engineer, Licensing T. Jordan, Manager, Systems Engineering M. Kanavos, Manager, Fluid Systems M. McBurnett, Licensing Manager l S. Melton, Supervisor, Configuration Control Section l S. Parthasarathy, Supervisor, Electrical Design R. Prater, Quality Consulting Specialist l R. Rehkugler, Director, Quality

! D. Rencurrel, Manager, Electrical / Instrumentation and Controls Design l D. Stark, Manager, Technical Support Engineering l S. Thomas, Manager, Design Engineering W. Wellborne, Supervisor, Instrumentation and Control Design NRC J. Keeton, Resident inspector W. Sifre, Resident inspector INSPECTION PROCEDURES USED IP40501 Licensee Self Assessments Related to Team inspections ITEMS OPENED AND CLOSED

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Opened

50-498/499/9624-01 NCV Three examples of inadequate design controls that were contrary to the requirements of 10 CFR Part 50,

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Appendix B, Criterion Ill.

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! 50-498/499/9624-02 NCV Two examples where the Updated Final Safety Analysis I j Report did not meet the requirements of 10 CFR Part )

! 50.71, in that, the report was inconsistent with actual

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plant condition !

l J 50-498/499/9624-03 NCV A minor violation involving three examples of a failure J

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j to adhere to plant procedure l

l', Closed l

l 50-498/499/9624 01 NCV Three examples of inadequate design controls that were 1 contrary to the requirements of 10 CFR Part 50, !

! Appendix B, Criterion Il !

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50-498/499/9624-02 NCV Two examples where the Updated Final Safety Analysis Report did not meet the requirements of 10 CFR Part 50.71, in that, the report was inconsistent with i actual plant condition .

50-498/499/9624-03 NCV A rninor violation involving three examples of a failure to adhere to plant procedure i

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LIST OF DOCUMENTS REVIEWED I Condition Reports CR N Title 96-12729 The drain nipple associated with valves 2-CH-0592 and 2-CH-0908 have stainless steel pipe caps installed which is not consistent with plant Specification 5LO19PS00 Evidence of sagging was discovered in the insulation on chiller 21 s 96-12740 The insulating washer for the 6" ECW return line to essential chiller 21 A flange connection is installed backward Water pockets were forming in the insulation on the lower half of the chiller (218) shell which can cause accelerated rust and corrosio Water pockets were forming in the insulation on the lower half of the chiller (21C) shell which can cause accelerated rust and corrosio ,

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- 96-13152 During a review of the setpoint index, discrepancies were ;

found between the scaling database and setpoint index.

l 96-13542 The T-Mod procedure does not list the fire hazards evaluation l j in the body of the procedure (as part of the technical review j question) but lists it in the references. This may lead to fire j i hazard evaluations being missed on T-Mods.

i-l 96-12815 Nuclear engineering self assessment: The integrating factor of i 2.6 for the 180 day doses in NC-9002 appears unreasonabl '

96-12860 Nuclear engineering self assessment item: Calc MC-6429

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should be revised to clarify the design basis of the essential chilled water system for cold weather conditions.

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! 96-12858 Nuclear engineering self-assessment item: Calc MC-6412 i should be revised for clarification purposes and its j requirements implemented in the CH DBD.

1 96-12763 During a review of the close-out documentation for the quality assurance essential chilled water safety system functional

assessment 93-03, it was identified that calculations MC-l 5232, MC-5274, and MC-5275 would be superseded.

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) 96-13194 Interviews with systems engineers, during the engineering self l assessment, identified problems in meeting two aspects of the j system expert plan .

W j 96-12792 OPOP02-CH-0001 (essential chilled water system operating j procedure) steps 4.25 through 4.31 contain actions required j during a safety injection or loss of offsite power. Are these j actions required so that the chill water system can perform its i

safety function?

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96-12772 While performing OPSP06-NZ-0006 (95006866 ST: j l 87001213) the set point did not match the data on the breaker j in the fiel !

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96-11080 CN-2063; Delete UFSAR Tables 1.3-1 and 1.3-2 and revise i text in Section 1.3 to explain deletio ,92-939 CN-1827; Revise UFSAR/FHAR to reflect replacement of ECW l driller outlet valve electro-hydraulic actuators to handwheels, j 96-12668 UFSAR Sections 1.3-10 and 7.5.6.1 and the essential chilled water DBD (5V369VB0120) 2.A.1.1.5 and 3.A.1. erroneously indicate ability to control essential chilled water

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from the auxiliary shutdown panel. In addition, the DBD 2.A.1.1.5 suggests that CH can be operated locally; however, there are no local controls for the pum CN-2022; Update UFSAR references in Tables 1. 3-2, 1. 6- 1, 1.6- (

96-13003 CN-2104; FSAR question 430.37N response is incorrect and doesn't fully answer the question. The first statement in the response states that the class 1E power system battery chargers are not capable of supplying power to DC loads

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unless connected to a battery. Actually the chargers can supply the de loads with the battery breaker open.

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96-12998 CN-2103; Editorial errors in the FSAR. Sections 8.3.2.1.1 and

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10A.2.4 on page 10A-8 both state that the class 1E 125 V battery buses are energized by both chargers. This statement

is contrary to actual plant operation and the remainder of the FSA The scope and framework of the design basis documentation l (DBD) program plan and the actual set of DBDs produced are,

in some cases, inconsisten The information given in OPSP06-DJ-0004./Rev 2 for performing a service load test on battery E1(2)D11 is not correct. Since the E1(2)D11 batteries have not been tested using the inaccurate load profiles given in OPSP06-DJ-0004, there is no operability /reportability impact.

96-13216 Management concerns have been raised with the use and

control of minor design changes. Some instances of excessive I budget impact and some instances of delayed incorporation of i plant impacts were identifie Mod 91-051 to add refrigerant clean up kit was determined to be a trivial change. Since the trivial change was being done to safety related equipment, this change does not meet the present definition of trivia in the essential chilled water PSA package, Section 1 (pg.19), OPSP03-CH-0004 is said not to affect availabilit OPSP03-CH-007, however, is noted to affect ECH flow I-through the air handling unit The casing vent lines and valves for the RCB chill water pumps 21 A,21B, and 21C are not per desig .

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96-12796 The setpoint index lists 30 degree F decrease setpoint for B2CH-TL-9510 EVAP REFRIG LOW TEMP alarm shutdown (trips chiller). The scaling document for this switch requires 1 32.5 degree F setpoint, j 96-12799 The setpoint index lists a required maximum reset value of 13.3 inches HG abs for this trip switch (REFRIG LOW PRESSURE). The scaling document requires no maximum rese l 96-12801 The setpoint index lists 24 psig decreasing setpoint for NICH-PSH-9612(2) switch to initiate " REFRIGERANT HIGH 1

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PRESSURE" light on ZLP-615. The scaling document for this switch setpoint requires a 30 psig setpoin A further review of electrical setpoint index database for setpoints applicable to the DJ system identified that the database does not reference electrical calculation EC-5033 which provides the setpoint bases and reference During a review of CR 96-5203, the CAP data base indicates that reportability and operability are " indeterminate". J l

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96-12814 During a review of CR 95-11341 and the associated CREE 95-11341-5, it was noted that calculation MC-5234 assumed a maximum peak CH pressure of 154 psi due to water hammer during a loss of nitrogen pressure on the train "C" CH expansion tan During the engineering assessment, a review o' the " design basis document" process revealed a number of problem During the review of PM EM-1-VA-93002770 performed on 5/27/96, it was discovered that the panel meter calibration data sheet for M3 has a minimum cardinal point at 200 of 3 recorded. This entry is incorrect and should have been 2 The "as found" input of 25.51 is acceptable and does not render the equipment inoperabl Design Change Packages DCP N Title 94-468,. 3 Overspeed setpoint change for TSC Diesel i

94-4683-3

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Overspeed setpoint change for TSC Diesel 96-13536-2 Abandon-in-place Time Delay Relay TD on TSC engine junction box

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l 96-13536-3 Abandon-in-place Time Delay Relay TD on TSC engine junction box

95-2724-1 TSC Emergency Generator Stator Temperature

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96-5950-4 Add Insulation to the Exhaust Line of the TSC Diesel d

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96-5950-5 Add Insulation to the Exhaust Line of the TSC Diesel 95-1724-4 BOP 1 DG Vibration Switch

2 95-1724-3 BOP 2 DG Vibration Switch 96-3265-10 Install Mirror and Correct Control Wiring in ZLP 138 96-3265-11 Install Mirror and Correct Control Wiring in ZLP 138 94 2639-3 TSC DG Lube Oil Temperature 96-12558-5 Revise Wiring for TSC Diesel to Correct Frequency Permissive to Breaker Closure 96-12558-6 Revise Wiring for TSC Diesel to Correct Frequency Permissive to Breaker Closure 96-999-1 Provide a Sample Point for the EOF, Lighting, BOP and TSC Diesel l

95-1854-2 Relocate TSC Diesel Starting Air Receiver Moisture Trap Valve from I the Bottom of the Tank to Structural Mounting Slab Near the Air i Receiver

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Temporary Modifications l T-Mod N Title T1 96-11616-2 Provide T-Mod to " dummy" in signal for Data A input for l Control Rod F6 i T2-96-3958-2 Provide T-Mod to " dummy" in signal for Data B~ input for Control Rod LS ,

Plant Proceaures Procedure Revision Title N OPOPO5-EO EOOO 7 Reactor Trip or Safety injection OPOP02-CH-0001 19 Essential Chilled Water System

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r OPGP03 ZO-003 17 Temporary Modifications CPGP03-ZX-0002 13 Condition reporting Process i

OPGPO4-ZA-OOO2 2 Condition Report Engineering Evaluation Program

OPGP05-ZA-0002 5 10CFR50.59 Evaluations 1 OPOP02-DB-0003 10 Balance of Plant Diesel Generator OPOP02-DB-0005 12 Technical Support Center Diesel Generator Miscellaneous Documents March 5,1996 Office Memorandum "EH and MS System Expert Development Plan" March 6,1996 Office Memorandum "TM System Expert Development Plan" South Texas Project Engineering Self-Assessment Final Report October 14-24,1996 Completed data from Data Package 1 (dated November 13,1996) and Pp 11 through 14 of Data Packcge Cove" " et (dated March 9,1991) of Procedure OPSP06-NZ-0006, Molded Case Circuit Breakt unctional Test and Inspection Updated Final Safety Analysis Report Review and Assessment of Programs that Maintain the Licensing Basis, dated October 17,1996 UFSAR Responsibility Matrix, dated January 8,1997 Office Memorandum dated Novernber 26,1996, from Steve Thornas to Distribution, subject: Design Basis Documentation Program (ST-HS-HS-035436)

9A019GB00001, Design Basis Documentation Program Plan, Revision 0, dated December 18,1996 Listing of Unit 1 and Unit 2 Installed Temporary Modifications, dated January 6,1997 System Description Cover Sheet, South Texas Project Job No. 14926-001, for the "Non-Class 1E Diesel Generators System Health Report for the Non-ESF Diesel Generators (DB, DL), dated July 8,1996 System Walkdown inspection for the DB System d 'd November 8,1996 System Walkdown Inspection for the DB System, TSC Diesel dated December 17,1996 SLO 19PS004, "WA Specifications", Revision 19 7