IR 05000489/1987037

Insp Repts 50-489/87-37 & 50-499/87-37 on 870413-0611.No Violations or Deviations Noted.Major Areas Inspected:Startup Program,Startup Procedure Review & Licensee Action on Previous Insp Findings

ML20234E399
Person / Time
Site:	South Texas, Perkins
Issue date:	07/01/1987
From:	Bruce Bartlett, Constable G, Hildebrand E, William Jones, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20234E366	List: IR 05000489/1987037 IR 05000498/1987037
References
50-498-87-37, 50-499-87-37, NUDOCS 8707070563
Download: ML20234E399 (13)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-37 Construction Permits: CPPR-128 50-499/87-37 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700 Houston, Texas 77001 i

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

Inspection At: STP, Matagorda County, Texas Inspection Conducted: April 13 through June 11, 1987 Inspectors: #

'G.L. Madsen, Reactor Inspector, Project 7/ /87 Date Section C, Reactor Projects Branch l

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~ W. B. Jones, Reslderit Inspector, Project 7AN7 Date Section A, Reactor Projects Branch i

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. P. Flildebrand, Reactor Inspector Dat'e '

Operations Section, Reactor Safety Branch Yn & Y'

'B. L. Bartlett, Residfnt Inspector, Project Date Section B, Reactor Projects Branch I

Consultants: G. Branson, N. Jensen, S. Roesener; EG&G Idaho In l l

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' J L. Constable ( Chief, Project Section C Date ,

Reactor Projects Branch i Inspection Summary Inspection Conducted April 13 through June 11, 1987 (Report 50-498/87-37; 50-499/87-37 Areas Inspected: Routine, announced inspection of overall startup program, startup procedure review, and licensee actions on previous inspection finding Results: Within the areas inspected, no violations of NRC requirements or j

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DETAILS i

d Persons Contacted Principal Licensee Employees

• H. Kinsey, Plant Manager

• J. W. Loesch, Plant Superintendent M. Robinson, Director, Independent Safety Evaluation

• G. L. Parkey, Technical Support Manager

• S. M. Head, Lead Engineer Licensing

• J. T. Westermeier, Project Manager

• D. Leazur, Reactor Performance Supervisor T..Godsey, Technical Support Engineer R. J. Daly, Startup Manager G. Ondriska, Lead Engineer, Startup In addition to the above, the NRC inspectors also held discussions with various licensee, AE, and other contractor personnel during the inspectio * Denotes those individuals that attended exit meetings on April 17, May 8, or June 11, 198 . Overall Startup Program The purpose of this inspection activity was to determine whether the ;

licensee has developed administrative controls which will assure that the startup test program will be prepared, performed, and evaluated in )

accordance with requirements. References utilized for this activity (

included: i Chapter 14 of the STP Final Safety Analysis Report (FSAR) Questions and responses to the FSAR numbers 423 and 64 NRC Regulatory Guide (RG) 1.6 STP startup procedures for administrative control test plateau 1 control, and specific test j Preoperational test procedures relating to the requirements for the startup progra ; STP - Measuring and Test Equipment control procedure I A review of the above referenced documents and discussions with STP personnel resulted in the following observations and conclusions:

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-4-a. Overall Test' Program (1) The overall test program includes the areas of core loading, initial criticality, low power. testing. .and power ascension testing. The plant manager has the overall responsibility for operation of the )lant. The technical support superintendent is responsible for t1e startup test program as delegated by the plant manager. The reactor performance supervisor is responsible to the technical support superintendent for the administration o the startup program, preparation of the test procedures, review of the test results, and ensuring the preparation of startup test report (2) A comparison of the FSAR and RG 1.68 commitments to the existing STP startup program was initiated'on March 30, 198 Twenty-three RG 1.68 line items were identified as requiring additional followup (0 pen Item 498/8708-05). As a result, the licensee developed a initial startup program document which included tables comparing.RG 1.68 and FSAR 14.2.12.3. requirements to the startup procedures containing coverage for the commitment The program document also includes a matrix which presents. test sequence plateaus for each test procedure. A review of th initial draft revealed the need for refinement regarding procedure references, omissions,'and typographical errors which the licensee incorporated in the revision which is circulating for final review and approva On April 13, 1987, the NRC inspectors continued the evaluation of the coverage of the startup program to the requirements of RG 1.68. Followup on the 23 RG 1.68 items identified during the .

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March 30, 1987, inspection revealed that HL&P was taking credit for preoperational testing (mainly hot functional testing) as a substitute for the required RG 1.68 startup testing. The NRC inspectors review of the FSAR, including questions and responses 423 and 640, revealed that the substitution of preoperational testing for startup testing had been evaluated by:NRR for some 14 RG 1.68 line. items. The NRC inspectors review of portions of applicable preoperational tests that were to serve;as substitutes for the startup program raised the following concerns: j l

(a) Containment temperature during hot functional testing '(HFT)

might not be clearly indicative of conditions encountered '

when operating at 100 percent' power for an extended perio (b) There appears to be a need for additional involvement in the evaluation of preoperational test results to be substituted for startup testing, by the reactor operations staff and the Plant Operations Review Committee'(PORC). Open item (498/8708-05)

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-5-As a result, HL&P committed to the collection of containment temperature data at 50 and 100 percent power to permit verification of the validity of the HFT result In addition, HL&P revised Procedure IPEP04-ZA-0001, Initial Startup Program Sequence and Administration. This procedure contains a control form entitled, "JTG-PORC Review of Preoperational Testing," which includes provisions for the following:

(a) A comprehensive review of preoperational testing by the joint test _ group (JTG) and PORC to provide assurance that the required systems are capable of supporting core loading and startup testin (b) Any preoperational testing which had not been completed has received JTG-PORC review and technical justification and scheduling of testing has been finalize (c) Review and approval by the JTG and PORC to confirm that preoperational test verified that systems will operate in

accordance with design for selected systems such as containment ventilation, engineered safety features (ESF)

pump room heat removal, residual heat removal (RHR) system performance, et With the incorporated revisions, the overall test program was found to fulfill the general requirements of the FSAR and RG 1.68 for startup testin In addition, Open Itea 498/8708-05 is considered closed, b. Test and Measurement Equipment The NRC inspectors reviewed Procedure OPGP03-ZM-0001, Revisior; 1, Measuring and Test Equipment Control Program, inspected the metrology laboratory, and interviewed licensee personnel. Additionally, the following measurement and equipment files were reviewed:

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ST-CC-6145 torque wrench / dial 150 ft/lb

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ST-CC-4044 torque wrench / dial 1000 ft/lb 100-00013-06 gauge / pressure 0-1000 psig 100-00076-01 gauge /diff. pres in. H 2O  ;

100-00711-B stop watch / digital 100-00205-05 volt-ohm-millianneter The above inspection activity provided verification that the test and measurement equipment program meets the requirements of the FSAR and RG 1.6 _ ______ _ ___ _ _ . .

-6-3. Startup Procedure Review Core Loading Procedure 1 PEP 04-ZL-0001, Revision 0, Prerequisites for Core Loading and IPEPO4-ZL-0010, Revision 0, Initial Core Loading were reviewe As a result of the review, the following was identified:

(1) Several differences between the two procedure (2) The need for a prerequisite in the core loading procedure addressing posting requirements of 10 CFR 20.20 (3) The need for a prerequisite addressing the completion of fuel and control rod inspections and resolution of problems identified prior to fuel loading.

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The licensee subsequently issued Revision 1 to these procedures. The l NRC inspectors review of these revisions revealed that the licensee had incorporated the suggested changes. As a result, both procedures meet the requirements of the FSAR Chapter 14 and RG 1.68.

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' Initial Criticality Procedure 1 PEPO 4-ZX-0002, Revision 1. Initial Criticality, and IPEPO4-ZX-0001, Revision 1, Test Sequence for Initial Criticality, were reviewed. As a result of the NRC inspectors observations and comments, the licensee issued Revision 2 to Procedure 1 PEPO 4-ZX-0002 and incorporated the needed reference. corrections, corrections of a predicted criticality note, and reference to a manual scram test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initiation of Boron dilution. With these changes, l both procedures are in agreement with the requirements of the FSAR l Chapter 14 and RG 1.6 During the review of the above two procedures, portions of the following procedures were also reviewed:

1) 1 PEP 04-ZX-0003, Boron End Point IPEP04-ZX-0004, Isothermal Coefficient Measurement IPEPO4-ZX-0006, Stuck Rod Worth Measuremen PEP 04-ZX-0007, RCCA Pseudo Ejected Rod Tes Pressurizer Effectiveness Test Procedure 1 PEP 04-ZL-0052, Revision 1, Pressurizer Spray and Heater Capability Test, was reviewed and found to meet the pertinent FSAR and RG 1.68 requirement i

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-7-d. Natural Circulation Procedure 1 PEPO 4-ZX-0010, Revision 1, was reviewed and found to meet the pertinent FSAR and Regulatory Guide 1.68 requirement e. Rod Drop Measurements The following procedures were reviewed:

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IPEP04-ZL-0023, Revision 0, Rod Drop Time Measurement (cold-no flow).

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IPEP04-ZL-0024, Revision 0, Rod Drop Measurements (cold-full flow).

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IPEPO4-ZL-0058, Revision 0, Rod Drop Time Measurements (bot-full flow).

The review of these procedures revealed discrepancies between the procedures. The licensee indicated that the three procedures were being consolidated into one procedure, 1 PEP 04-ZL-0024, Revision 1, Rod Drop Measurements. The procedure review also revealed the follcwing comments and concerns:

(1) The procedures stipulate that Digital Rod Position Indication (DPRI) operability must be verified each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during drop time test performance; however, documentation requirements were not include (2) Prerequisites requiring the plant to be filled and vented, RCCA mechanical tests completed, solid state protection system in service, or DPRI operable was lackin (3) The procedures required RCS temperatures to be greater than 540'F for hot drop times testing; however, Technical Specification 3.1.3.4 requires drop times to be measured at ;

greater than 561' (4) Inconsistencies between procedures were observed regarding the information to be noted on oscillograph traces which measure drop times, i i

(5) Discrepancies were found between the procedures reviewed ,

concerning identified rod grid locations on data sheet l

(6) The acceptance criterion of less than 2.8 seconds drop time during hot-full flow testing had no reference sourc Additionally, the existing procedures did not address hot-no flow rod drop time testing as~ required by RG 1.68.-

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-8-The licensee subsequently issued Procedure IPEPO4-ZL-0024, . Revision 1, Rod Drop Measurements, which consolidated the three original procedures, includes provisions for hot-no flow testing, and the six inspector concerns listed abov The revised procedure meets the requirements of the FSAR and RG 1.6 f. Reactor Coolant Leakage The NRC inspectors review revealed that Procedure 1 PEP 04-ZL-0050, Test Sequence For Hot Precritical Testing, requires the performance of Procedure IPSP03-RC-0006, Reactor Coolant Inventory, as the first test following heatup. A review of this procedure revealed that precautions were lacking which could result in invalidation of the tes Subsequently, the licensee issued a field change to IPSP03-RC-0006. A review of the field change revealed inclusion of the necessary precautions. The existing procedure coverage meets the requirements of the FSAR and RG 1.6 g. Low Power Testing The review of Procedure 1 PEP 04-ZX-0001, Revision 1, Test Sequence for Initial Criticality and Low Power Testing revealed the need for:

(1) A step or precaution defining a startup rate limitatio (2) A need to expand the test objectives to include differential boron worth calculation (3) A need to include a statement on expected criticality, critical rod heights, what actions to initiate if criticality is achieved at an unexpected rod height, and prohibition on adding positive reactivity by more than one method at a tim The review of Procedure 1 PEPO 4-ZX-0003, Revision 1, Boron Endpoint Measurement revealed the need for:

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A clarification to the test method section regarding the l meaning of specific positions

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Reconciliation of a note on page 7 which does not coincide .

with the data sheet 2 requirements The review of Procedure IPEP04-ZX-0004, Revision 1, Isothermal Temperature Coefficient Measurement revealed a need for notification of the shif t supervisor if the moderator coefficient is positiv >

The review of Procedure IPEP04-ZX-0006, Revision 1, Stuck Rod Worth Measurement revealed a need for adding a statement on expected critical rod height and actions to be taken if criticality.is achieved at an unexpected rod height; also a need for temperature correction for boron calculatio I i

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-9-Subsequently, HL&P issued Revision 2 to the above five procedures. A review of the revised procedures revealed inclusion of responses to the NRC inspectors comments and that the procedures meet the requirements of the FSAR and RG 1.6 h. Core Performance The following procedures relating to core performance were reviewed:

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- OPEP02-ZG-0010, Revision 0, Calorimetric.

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- IPEP04-ZA-0001, Revision 1, Initial Startup Test Program Sequence and Administratio IPEPO4-ZG-0004, Revision 0, Operational Alignment of Nuclear Instrumentatio IPEPO4-ZY-0015, Revision 1, Statement Data Collectio IPEP04-ZY-0020, Revision 0, At Power Calibration of Steam and Feedwater Flow Instrumentatio IPEP04-ZY-0030, Revision 2, Initial Synchronization and 30 percent Power Tes IPEP04-ZY-0040, Revision 0, Initial Adjustment of Nuclear Instrumentatio IPEP04-ZY-0050, Revision 2, Test Sequence at 50 percent Powe '

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IPEP04-ZY-0054, Revision 0, Preliminary Incore-Excore Detector Calibratio IPEP04-ZY-0070, Revision 2, Test Sequence at 75 percent Powe IPEP04-ZY-0090, Revision 1, Test Sequence at 90 percent Powe PEPO 4-ZY-0100, Revision 2, Test Sequence at 100 percent Powe OPSP10-II-0004, Revision 0, Determination of Quadrant Power Tilt Ratio Using Incore Instrumentatio OPSPIO-NI-0001, Revision 1. Target Axial Flux Determination The review of OPEP02-ZG-0010 revealed that data sheet 3, equation 9 was incorrect and that on data sheet 4 the pump heat constant was incorrect. HL&P issued Revision 1 to the procedure which included the necessary correction The review of Procedure IPEPO4-ZY-0015 revealed that the MW thermal equation on data sheet 7, page 3, was miswritten and the equation for

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rated thermal power needed to be multiplied by 100. . Additionally, there were equations on data sheet 7, pages 1 and 2, which were incorrect;and were not consistent'with Procedure OPEP02-ZG-0010,;

Revision 0. Subsequently, HL&P issued Revision 1 to the procedure which provided the needed correction '

'The review of Pror.edure IPEPO4-ZY-0030. Revision 2, revealed that step 4.8 stated that the'~ RCCA selector switch should not be placed in

' automatic cat 11 after 1 PEP 04-ZY-0031 ~ is performed yet step 6.1 states perform IPEP04-ZY-15-prior.tofperforming IPEP04-ZY-0031.

l 1 PEPO 4-ZY-15 calls for' placing. rod control in automatic. HL&P revised

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1 PEP 04-ZY-0015 which corrected'the confusion. Additionally, IPEP04-ZY-0030, step 6.14.3_was!in need of evaluation.and acceptance criteria for' flux map data. HL&P issued Revision 3 to provide the

' criteri The review of IPEP04-ZY-0030, Revision 2 revealed a reference to OPOP02-II-0001'which had not been issued. Revision 0 of this procedure was issued :on' May-26,198 The review of IPEP04-ZY-0054' Revision O', revealed the need to define

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the various symbols' being used and a reference to Procedure IPEP04-ZY-0014 which did not exist. HL&P31ssued Revision 2 to Procedure IPEP04-ZY-0054 which provided for the necessary l correction.

l The review of Procedure 1 PEP 04-.ZY-0100, Revision 2, revealed the need L for acceptance' criteria for~ evaluating flux maps and that steps 6.13 and 6.14 were reversed.- Revision 3 to the procedure was issued to correct the NRC inspectors finding The review'of a draft of Procedure OPOP02-II-0001', Incore Moveable-Detector Operation revealed that it did not call for informing the shift supervisor or health physics prior to' moving the incore probe A review of the finalized procedure revealed that adequate prerequisite steps were' incorporated into the procedure.

l The procedures for the testing above meets the requirements to the l FSAR and RG 1.68.

, Generator Trip Test The review of Procedure 1 PEP 04-ZY-102, Revision 1, plant trip from 100 percent power (generator trip), revealed that the applicant had not addressed a FSAR acceptance criteria that no safety limits are .

exceeded. HL&P issued Revision 2 to the procedure which incorporated an acceptance criteria to ensure that the safety limits of Technical Specifications 2.1.1 and 2.1.2 are not exceeded. The existing procedure meets the requirements of the FSAR and RG 1.68.

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k j. Loss of Offsite Power The ieview of Procedure IPEP04-ZY-0034, Revision 0, Loss of Offsite Power test revealed several references to Emergency Operating Procedures (E0Ps)directingthatspecificoperationsbeperformedin accordance with the E0Ps. These directions are contrary to the Emergency Response Guidelines which call for E0Ps to be entered and executed in a specific sequence. HL&P indicated that the procedure was being revised and the problem regarding the reference to the E0Ps was being addressed. Revision 1 of the procedure was issued and wa reviewed by the NRC inspector and some of the relationships between the procedure and the E0Ps had not been corrected. HL&P subsequently prepared Revision 2 to Procedure 1 PEP 04-ZY-0034. This revision incorporates the needed corrections in the relationships between the procedure and the E0Ps. Revision 2 to the procedure meets the FSAR l

and RG 1.68.

Discussions with Hi&P revealed that a request for relief from the performance of a Loss of Offsite Power test had been sent to NRR; however, to date the relief had not been granted. This is being tracked in connection with Open Item 498/8731-0 k. Shutdown From Outside the Control Room The review of Procedure 1 PEP 04-ZY-0035, Revision 1, Shutdown From Outside the Control Room revealed an incorrect reference to Procedure IP0PO4-ZY-0001. HL&P issued Revision 2 to the procedure which eliminated the incorrect reference. The existing procedure ,

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meets the requirements of the FSAR and RG 1.6 '

l. Flux Asymetry

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The review of Procedure IPEP04-ZY-0051, Revision 0, Flux Asymmetry revealed the following:

(1) The prerequisite steps did not define " stable."

l (2) There were four references to Procedure 1 PEP 04-ZY-0014 which had been previously deleted.

l (3) Some acceptance criteria and equations were out-of-date with respect to the the latest draft of the Technical Specification j l

l (4) The procedure failed to meet the RG 1.68 requirements of being-

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able to detect control rod misalignments of less than or equal to the Technical Specification limit of 12 steps.

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HL&P issued Revision 1 to the procedure which resolved the above 4 concerns; however, some editorial and typographical errors were noted

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-12-during the inspectors revie HL&P prepared Revision 2 to the Procedure 1 PEPO 4-ZY-0051 which provided the needed correction The existing procedure meets the requirements of the FSAR and RG 1.68.

i .At-Power Pseudo Rod Ejection Test

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A review of Procedure 1 PEP 04-ZY-0036, Revision 1, At-Power Pseudo Rod Ejection Test revealed:

(1) steps were in need of references for flux map procedures (2) the test purpose and criteria needed clarification HL&P prepared Revision 2 to the procedure which addressed the abov The existing procedure meets the requirements of the FSAR and RG 1.68, Thermal Expansion and Vibration Monitoring Procedures IPEPO4-ZG-0008, Thermal Expansion Movement and IPEPO4-ZG-0010, Vibration Monitoring were not available for revie HL&P is presently finalizing the evaluation of-the hot' functional results relating to these creas of testin The completion of the Thermal Expansion and Vibration Monitoring procedures will be tracked as Open Item 498/8737-0 . Operational Staffing During the March 30, 1987, inspection, the manager of reactor operation position vacancy, the overall level of nuclear operations experience, and the implementation of the Independent Safety Evaluation Group (ISEG) was identified as requiring followup (0 pen Item 498/8708-07). Discussions with HL&P personnel revealed the following: The plant organization has been restructured. The Plant Superintendent position has been eliminated and J. W. Loesch has been assigned to the position of Manager, reactor operations. Additionally, HL&P has hired an operational advisor to the Manager, Reactor Operations who possesses over 18 years of nuclear operations experience, The overall depth of nuclear operations experience of the present staff is considered equivalent to that presented in the FSAR. HL&P provided initial notification of the reorganization to NRR by letter dated June 4, 198 The five positions of the ISEG had been filled by May 18, 198 )

Additionally, the NRC inspector was informed that the control procedures for the ISEG were also in place by May 18, 198 Discussions with HL&P personnel indicated that 'the qualifications of the ISEG staff is adequate and the ISEG is functiona ,

With the above, Open Item 498/8708-07 is considered close ,

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-13-5. Exit Interviews

The NRC inspector. met with licensee representatives (denoted in paragraph 1) on April 17, May 18, and June 11, 1987, and summarized the scope and findings of the inspection

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