IR 05000498/1993046

Insp Repts 50-498/93-46 & 50-499/93-46 on 931129-1203.No Violations Noted.Major Areas Inspected:Effectiveness of Licensee Improved post-maint Testing Program

ML20059B372
Person / Time
Site:	South Texas
Issue date:	12/28/1993
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059B366	List: IR 05000498/1993046 ML20059B362
References
50-498-93-46, 50-499-93-46, NUDOCS 9401040102
Download: ML20059B372 (9)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION ,

REGION IV  ;

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Inspection Report: 50-498/93-46 [

50-499/93-46

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Licenses: NPF-76 NPF-80 $

Licensee; Houston Lighting & Power Company P.O. Box 1700 Houston, Texas Facility Name: South Texas Project Electric Generating Station (STPEGS),

Units 1 and 2 Inspection At: Matagorda County, Texas Inspection Conducted: November 29 through December 3, 1993 Inspectors: T. O. McKernon, Reactor Inspector, Project Section A, Division of Reactor Projects 'l R. B. Vickrey, Reactor Inspector, Engineering Section, ,

Division of Reactor' Safety ,

(4 Approved: 1lI , A ti6n A h ZNO Date , '

W. D. Jo r f, Pfroj CC16 I

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Inspection Summar_y Areas inspected (Units I and 2): Routine, announced inspection to ascertain  ;

the effectiveness of the licensee's improved postmaintenance testing (PMT)

progra Results (Units 1 and 2):

. The improved PMT program resolved many of the problems of the prior progran; however, some implementation weaknesses still exist. (Section 2)

• The licensee was effective in identifying and pursuing problems related ,

to the PMT program. (Section 2) -

9401040102 931228 PDR ADOCK 05000498-G PD !

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Summar_y of Inspection Findings:  ;

• Inspection Followup Items 498;499/9331-03, -04, -07, and -10 remain open pending followup on other associated Restart Issues. However, these items are considered closed with respect to Restart Issue.4. (Section 2.2)

• Inspection Followup Items 498;499/9331-15, 79 remain open pending future i inspection on the progress of the procedure upgrade programs. (Section ,

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+ Inspection Followup Item 498;499/9331-63 was closed. (Section 2.3.1)

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Attachment:  !

Attachment - Persons Contacted and Exit Meeting

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DETAILS

i 1 BACKGROUND t Both units at STPEGS were shut down in early February 1993, and remain ,

shutdown as a result of numerous broad scoped problems identified by the NRC and the license ;

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NRC Inspection Report 50-498/93-31; 50-499/93-31, issued on October 15, 1993, identified 16 Restart Issues that required resolution prior to the restart of Unit 1. In addition to these Restart Issues, a number of items related to these Restart Issues were identifie In addition, NRC' Inspection Report

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50-498/93-39; 50-499/93-39 evaluated programmatic changes the licensee had -

made to the PMT program. The purpose of this inspection was to determine the licensee's effectiveness in resolving Restart Issue No. 4, "Postmaintenance ;

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Test Program" by reviewing those items not previously reviewed by the above programmatic inspection. Further, by evaluating the effectiveness of the PMT implementation establish a basis for concluding that this Restart Issue has been adequately resolved by the license ACTIVITIES ASSOCIATED WITH IMPROVING IMPLEMENTATION OF THE POSTMAINTENANCE :

TESTING PROGRAM (92720)

2.1 Resolution of PMT Related Deficiencies During the NRC Diagnostic Evaluation conducted at STPEGS from March 29 through April 30, 1993, a number of concerns related to PMT and not yet reviewed were identified:

• Shift supervisors and their control room staff could not effectively !

maintain the proper focus and overview of plant operations because of l their participation in administration' programs and resource-intensive i'

surveillance * Poor support to operations was adversely impacting the licensee's capability to safely operate the plan ,

• Maintenance and testing weaknesses reduced the reliability of l safety-related and balance-of-plant equipmen * Surveillance and postmaintenance testing did not always verify equipment ;

operabilit ,

• Testing procedures did not ensure all Technical Specification surveillance requirements were being me ,

• A test system for system performance software had not been initialized onsit .

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• Work procedures occasionally contained unneeded information and did not  :

match the experience of the individuals using the procedure !

Procedures were sometimes ignored and often revised to correct error [

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The licensee had addressed each of the above deficiencies with respect to improving the PMT process. The improvements included such things as the establishment of the operations work control group (0WCG) for review of work *

packages and work start authority, and enhancement of surveillance testing procedure . Administrative Burden of the Shift Supervisors and Control Room Staff  !

Reduced In order to reduce the administrative burden of the shift supervisors and the control staff the licensee established the 0WCG. The 0WCG's function was to review service requests (SRs), approve the integrated schedule, develop and authorize Equipment Clearance Orders (ECOs), specify and coordinate ,

operability tests, coordinate PMT and postmodification testing, and reviewing and prioritizing forced outage work lists, and by specifying the work start ,

authority (WSA). The 0WCG would advise the shift supervisor on concerns '

affecting operability, safety, or reportability and perform an evaluation to '

determine if the condition was previously identified and other attributes defined in the Work Process Program Procedure, OPGP03-ZA-0090, Revision .

Discussions with key operations personnel indicated that the 0WCG had  :

significantly reduced the administrative burden in that approximately one-half work day was saved by having the 0WCG review work package Further, one SS estimated that 3 to 4 days were saved prior to mode changes. The SS interviewed believed that the 0WCG allowed him greater time to oversee '

operator activities at the control boards and more in-plant time to observe the performance of key activities. By having the 0WCG under the direction of a licensed senior reactor operator and staffed with representatives from the operations, scheduling, planning and maintenance departments, the licensee ensured that the shift supervisors and control room staff were relieved of a  !

significant administrative burden during normal hours of operatio .1.2 Poor support to operations was adversely impacting the licensee's capability to safely operate the plant During the diagnostic evaluation it was noted that degraded equipment, ,

inadequate support to computer information systems, and numerous Technical Specification inconsistencies created unnecessary obstacles for the control ,

room staff. In many instances the conditions created operator work-arounds ,

and significant time delays in performing surveillance tests. Examples included: the absence of permanently-installed flow measuring devices to support routine pump flow surveillances in safety-related systems;. problems with solenoid-operated valves which required operators to take timely local

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actions to compensate for the inadequacies; manual throttling of temperature control valves (TCVs) and their associated bypass valves to control the cooling of various systems; and a number of information systems which contained errors that caused operators to rely upon other uncontrolled data system *

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l During this inspection, the inspectors verified that the licensee had taken ,

corrective actions to improve the computer information system used by the operators and the 0WC The two keys systems (Operability Tracking Log and i the Equipment Clearance Order) had been verified and were in the process of 'i being validated. The verification process entailed test runs of program software. The validation process of the operations software and associated j databases will ascertain the accuracy of the systems and is scheduled to be !

completed prior to April 1994. Other actions verified by the inspectors -

e included the reduction of inoperable automatic functions discussed in NRC j Inspection Report 50-498/93-53; 50-499/93-53; precision calibrations performed

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on flow instrumentation to support surveillance testing; management review of ,

components on increased surveillance testing frequency; status of solenoid l operated valves; and upgrading of computer information systems and software i programs. Automatic functions involving TCVs have been modified during the ;

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outage and await testing during plant startup. Issues related to solenoid-operated valves have been reviewed and closed in NRC Inspection Report 50-498/93-45; 50-499/93-45. Issues related to increased surveillance frequency on safety-related components remains to be reviewed. However, at the time of this inspection, the licensee had steadily decreased the total !

number of items on increased testing frequency and was close to their target ;

goal of less than twenty. The licensee's review of this item had not been i completed and would not be performed until shortly before plant start-up. The :

licensee stated that any components that cannot be taken off increased testing !

frequency will be evaluated for operations impact prior to plant start u !

From the areas discussed above, it appeared that the licensee had taken $

numerous corrective measures to improve support to operations from other site ;

organizatio ;

2.1.3 Maintenance, Surveillance, and Postmaintenance Testing weaknesses Reduced the Reliability of Equipment The diagnostic evaluation identified that in several instances weak maintenance practices, surveillance testing, and postmaintenance testing left ;

equipment in an unreliable condition to support operation ;

During this inspection, the postmaintenance testing program implementation ,

effectiveness was evaluated. A sampling of completed work packages was '

reviewed for adequacy of PMT requirements. The review identified weaknesses '

in the PMT program implementation in that some work order sheets inconsistently specified PMT requirements while other work instructions a specified PMT requirements which were inconsistent with the guidelines of the PMT reference manual. Discussions with key maintenance managers indicated that some of the examples were attributable to the training of the maintenance planners. One example involved the disassembly, repair, and rebuild of the ;

1. 13 Starting Air Compressor. The inspectors questioned the PMT requirements F in that they were inconsistent with the PMT reference manual testing attributes and did not include several of the attributes. Since the work l involved a total rebuild of the compressor, the expected PMT requirements would include those industry practices used to establish a new reference data l

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baseline for the equipment. The PMT reference manual included these !

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acceptance criteria attributes such as bearing temperature monitoring, oil levels, oil temperature and others, but were not included in the work package ,

instructions. The PMT instructions provided in the work package mimicked the i operability RUN test attributes of verifying proper operation (i.e., ability to pump up to pressure, no leaks or abnormal conditions, and correct lubrication oil levels). Another example included not specifying torquing verification when torquing had been accomplished during the work activit The inspectors also reviewed MWR:DG-315176 for ESF DG #23 annunciator panel ;

ZLP 0106. Work instructions under WAN #93035324 provided instructions to determine the fault causing the power supplies for DG #23 to blow fuses and !

correct the problem. The inspectors noted that the work order cover sheet t indicated no PMT required while the work instructions contained a step with PMT requirements. Furthermore, the inspectors questioned the adequacy of the .

FMT requirements of the work instructions since the licensee's PMT Reference Manual contained several additional PMT requirements for annunciators that were not included in the work instructions but were appropriate in accordance of the PMT test matrix. Followup discussions with key maintenance personnel ,

indicated that the problem with inconsistencies in the PMT instructions may :

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have been the training provided to the maintenance planner :

2. Conclusion  ;

The inspectors concluded that while the sample size of completed work packages reviewed was small, the number of packages with errors (about 25 percent)

indicated that the PMT program had implementation weaknesses. These weaknesses were characterized as inconsistencies amongst planners in filling out the work order sheet to inconsistent usage of the new PMT reference manual in specifying PMT requirements. Corrective actions by the licensee to resolve these implementation weaknesses will be reviewed during NRC Inspection l 50-498/93-54; 50-499/93-5 '

2.2 OPEN ITEMS RELATED TO RESTART ISSUES (92701)

2.2.1 (0 pen) Inspection Followup Item (IFI) 498:499/9331-13: PMT Program and Implementation Weaknesses This IFI involves weaknesses associated with the PMT program and relates to ,

more than one Restart Issue (i.e., 4, 11, and 12). t This IFI will remain open until weaknesses associated with the PMT program implementation have been addressed by the licensee and a satisfactory basis for closure of the Restart Issue has been establishe .2.2 (0 pen) Inspection Followup Item 498:499/9331-15: Previous licensee event reports and NRC enforcement actions documented that the licensee's '

testing procedures did not ensure all Technical Specification

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surveillance requirements were being me <

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Numerous instances had been identified where procedures were inadequate to meet Technical Specification surveillance requirements, thereby reducing assurance that the equipment was operable. Among these was a failure to completely test a manual reactor trip handswitch and the nonconservative  :

setting of one of the four reactor protection channels during a reactor startup. To address these inadequacies, the licensee committed to perform a .

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sample review of Technical Specification surveillance tests and verify their technical adequacy. The licensee's sample indicated that the Technical .

Specification surveillance program needed strengthening but did appear to satisfy Technical Specification. The licensee later committed to enhance the '

Technical Specification surveillance procedures. (M&TS of DET para.2.2.8,

" periodic Testing Not Always Effective")

A surveillance Procedure Enhancement Program has been initiated. A pilot program is on schedule for completion by the end of the year. Completion of '

the project is currently scheduled for the end of 1996. Because of changes in scope and experience gained during the pilot project, it is likely that this date will be extended. The licensee revised the writers guide OPGP03-ZE-0005, Plant Surveillance Procedure Preparation, Revision 11, effective October 20, 1993. They had completed ten of the fifty one procedures in the pilot program :

by December 1,1993, and were on schedule to complete the remaining forty one l

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by their target date of December 17, 1993. The 51 high priority procedures in the pilot program consisted of those that had caused or were similar to those that had caused problems in the pas !

2.2.2 (0 pen) Inspection Followup Item 498:499/9331-79: Work procedures occasionally contained unneeded information and did not match the experience of the individuals using the procedures. Procedures were sometimes ignored and often revised to correct error (M&TS of DET para. 2.2.6. " Inefficient Work Control Process")

A Maintenance Procedure Upgrade Program is in progress to provide a consistent $

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format, level of detail and conformance with Vendor Manuals- and Design Basis Documents. Also included is the generation of additional necessary

procedures. As of November 13, 1993, 89 procedures had been developed and 31 '

had been approved. They were behind schedule by 69 developments and 100 approval s. A recovery schedule had been submitted to bring them back on schedule. The licensee's assessment of the Maintenance Procedure Upgrade Project, dated November 19, 1993, stated that the recovery schedule seemed to be an unrealistic goa l A surveillance Procedure Enhancement Program is in progres (See IFI 9331-15 above)

The Planners Guide has been revised to provide improved guidance on how to develop Work Instructions and Preventive Maintenance Tasks, elimination '

unnecessary information. The Planners Guide was approved September 27, 1993, and effective October 1, 199 :

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! CLOSED ITEMS RELATED TO RESTART ISSUES (92701)

2.3.1 (Closed) Inspection Followup Item 498:499/9331-63: A test system for <

the system performance software will be initialized onsite. (IFIs j identified in the ORP item 72) q

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I The test system for the System Performance Monitoring (SPM) software has been developed and installed on the Local Area Network. This interim program has been demonstrated functional in trend file generation, data collection, and data management. Data is automatically collected on a Proteus computer system memory grabbe SPM data manager user instructions have been developed and issued to users. The system appears to be an excellent tool for system engineers in monitoring systems and analyzing performance data, t

3 LICENSEE'S EFFECTIVENESS IN IDENTIFYING, PURSUING, AND CORRECTING PLANT PROBLEMS (92720)

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It was noted that the technical support engineering group was established to assist operations and maintenance support thus reducing the burden previously placed on the operators. Further, the establishment of the 0WCG greatly '

relieved the shift supervisor and control room staff from the technical review burden of PMTs and work packages which previously diverted much of the control ,

room staff's attentio t

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ATTACHMENT 1 PERSONS CONTACTED 1.1 Licensee personnel ,

J. Blevins, Supervisor, Records Management and Storage B. Bragg, Maintenance Supervisor B. Caldwell, Assessor, Planning and Assessment J. Calloway, Planning and Assessment *

T. Cloninger, Vice President Nuclear Engineering W. Cottle, Group Vice President Nuclear .

M. Coughlin, Senior Licensing Engineer '

P. Dahl, Licensing J. Fast, Maintenance Manager, Unit 1 R. Ferguson, Licensing -

J. Finch, Secretary C. Glen Walker, Manager, Public Information J. Gruber, Unit 1 Work Cont *ol Supervisor S. Head, Licensing J. Johnson, Supervisor Qua'ity Assurance R. Kerr, Senior Independent Safety Evaluation Group Engineer L. Martin, General Manager, Nuclear Assurance

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P. Parrish, Senior Specialist, licensing R. Rehkugler, Manager, Quality Control  :

K. Richards, Unit 2 Work Control Manager l

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P. Schrimpf, Assessor, Planning and Assessment J. Sheppard, General Manager, Nuclear Licensing

C. Stephenson, Licensing Engineer-t i

In addition to the personnel listed above, the inspectors contacted other t personnel during this inspection perio ,

1.2 NRC Personnel M. Satorius, Project Engineer, Project Section A, Division of Reactor Projects J. Tapia, Reactor Engineer, Operations Section, Division of Reactor Safety D. Loveless, Senior Resident Inspector, South Texas Project

r G.'Werner, Resident Inspector, Comanche Peak  :

The above listed licensee and NRC personnel attended the exit meetin EXIT MEETING An exit meeting was conducted on December 3. 1993. During this meeting, the I inspectors reviewed the scope and findings of this report The licensee did ,

not take exception to any of the inspection findings, and did not identify as i

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proprietary any information provided to, or reviewed by, the inspector l

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