IR 05000498/1985024

Insp Repts 50-498/85-24 & 50-499/85-21 on 851201-860131. Violation Noted:Failure to Maintain Design Control & Failure to Follow Procedures

ML20138B089
Person / Time
Site:	South Texas
Issue date:	03/10/1986
From:	Breslau B, Carpenter D, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138B068	List: IR 05000498/1985024 ML20138B064
References
50-498-85-24, 50-499-85-21, NUDOCS 8603200277
Download: ML20138B089 (9)

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s APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

'NRC Inspection' Report: 50-498/85-24 . Construction Permit: CPPR-128 and 50-499/85-21 CPPR 129 Expiration Date: December,'1987 and December,1989 Dockets: 50-498 and 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P.' O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: December 1,1985 - January 31, 1986 Inspectors: y

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R. Carpinter, Resident Inspector-3 Date'

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/ Project Section C, Reactor Projects Branch l

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B. A. Breslau, Project Engineer Date Project Section C, Reactor Projects Branch Approved: -j -

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7 .~1. Tonstable, Chief, Project Section C Date'

Reactor Projects Branch O

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. Inspection Summary Inspection Conducted December 1,1985 - January 31, 1986 (Report 50-498/85-24; 50-499/85-21 Areas Inspected: Routine, unannounced inspection included site tours, licensee'

action on previously identified items, operations, training and startup testing activities, fitness for duty and pressurizer instrumentation orifices. The inspection involved 240 inspection-hours ~ onsite by two NRC inspector ~

Results: Within the scope of this inspection, one unresolved item and two violations were identified and are discussed in paragraph 6 (failure to maintain design control and failure to follow procedures).

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DETAILS

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' Persons Contacted a

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. Principal Licensee Employees i

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• P. Evans, Project Compliance Engineer

• R. Daly, Startup Manager

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! *S. Dew, Deputy Project Manager '

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.... *T. J. Jordan, Project QA Manager i *W. H. Kinsey, Plant Manager-

• A. J. Peterson, Startup 4 *J. T. Westermeier, Project Manager '

i *K. M. O'Gara, Project Compliance Engineer

! F. Alkov, Material Control Supervisor - i i *G. S. Shukla, Project Compliance Engineer

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D. R. Keating, Operations QA General Supervisor i *R. C. Arthurs, Project QA General Supervisor j *M. S.- Whittaker, Metrology Laboratory Supervisor

! *A. lC. McIntyre, Principal Engineer *

l *M. T. Sweigart, Operation QA Supervisor Other Personnel

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Bechtel Power Corporation (Bechtel)

i L. Hurst, Project QA Manager j R. D. Bryan, Deputy Project Manager, Construction

*J. B. Gatewood, Project QA Manager

• R. H. Medina, Lead QA Engineer

J. T. Minor, Deputy Site Engineering Manager

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• M. H. Alexander, Materials Manager

• A. K. Priest, Site Manager I

f Ebasco Services, Inc. (Ebasco)

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A. M. Cutrona, QA Manage . M. Zaist, Construction Manager l

J. A. Thompson, Deputy Construction Manager j Westinghouse

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• A. Hograth, Site Manager

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The NRC inspector also interviewed additional licensee personnel, Bechtel

< personnel, and other contractor personnel. during this inspection.

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• Denotes those individuals attending the exit interview conducted on January 31, 198 . Site Tours >

The NRC inspector conducted site tours both independently and accompanied by licensee and contractor personnel. These tours were made to assess the protection of inplace safety-related equipment, plant status and to observe construction, testing' and maintenance activities. The areas toured included: Unit 1; Nechanical and Electrical Auxiliary Building (MEAB), Fuel Handling Building (FHB), Diesel Generator Building, Reactor Containment Building (RCB), and safety-related equipment of the Turbine Generator Building; Unit 2; MEAB, FHB, and RCB; Balance of Plant (B0P):

Emergency Cooling Pond and Pump House, warehouse and equipment laydown areas, Reactor Operations Training Simulator facility and various nonsafety support facilities. Within the noted areas, activities were generally acceptabl No violations or deviations were identifie . Licensee Action on Previously Identified Items (0 pen) Violations (8515-01 and 8514-01) Failure to Maintain Permanent Plant Equipment This violation concerns the failure to maintain, protect and control the requisite quality of the safety-related permanent plant equipment as established by the Permanent Plant Maintenance (PPM) and Maintenance Action Card (MAC) system .

During this inspection period, the ongoing verification of the PPM program was completed and the repair activities continued. The following are the results of the verification and crafts retraining program. The data is for both safety and nonsafety equipmen PPM Activity No. of Items Retraining Status % Unsatisfactory

. Inplace 299 Complete see note 1 Protection (1) ,

. Filter 766 Complete see note 1 Naterial (1)

. Cosmoline (1) 506 Complet see note 1

. Grease (2) 537 Complete 42%

. Oil (2) 409 Complete 41%

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[ -5-c PPM Activity No. of Items Retraining Status % Unsatisfactory

. Heat (2) 1513 Complete- 8% (including meggering activities )

. Purge (2) 442 Complete no MD's written -

corrected when

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. Megger(2) 978 Complete see heat

. Batteries (2) 56 Complete already-turned over to Startup for MD's 5510 Note: (1) Items performed prior to 7-1-85 are not documented sinc they were completed prior to formalizing the PPM verification progra (2) After July 1, 1985, 100% Verification will include the following:

a) Visual inspection and documentation of all MAC items by craft, supervisor and QC (safety-related).

b) Classroom training of crafts documented by training roste c) On-the-job training of craft by supervisors during visual inspection activit An additional 1,617 items were not 100% verified because they were on nonsafety support equipment or they were currently undergoing refurbishment by the vendo The NRC inspector has reviewed selected verification review sheets, Maintenance Discrepancy Reports (MDs), verification program follow-up reports and crafts training lesson plans and attendance sheets. The NRC inspector has attended selected crafts training sessions. The disassembly of safety-related HVAC fan motors in the Fuel Handling Building for overgreasing verification and refurbishment was observed. These motor were suspected of being overgreased and disassembly confirmed the grease problem. All suspect motors will be disassembled and the bearings replace with the proper type and amount of grease. The vendor representative, Joy-Reliance, is performing the refurbishment. The document reviews and observations of licensee's actions were reasonable and acceptable. This item will remain open pending completion of equipment refurbishing and establishment of an acceptable baseline for the revised PPM and MAC systems.

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-6-Licensee Action on Previously Identified Items (0 pen) Violation 8507-01 This item refers to a previous inspection finding which involved procedure noncompliance within the M&TE control progra A_ review of the corrective steps taken by the licensee indicates that the-Tool Data Issue / Record Cards are not being annotated with the required data specified in -procedure PGP3-AM-01- and QCP 12.1. . An entry is required by the supervisor of the user to be entered on the Tool Data Issue / Record Card when M&TE equipment is used on "non-safety related activities."

Twenty (20) Record Cards were observed to be missing this entr Additionally,- PGP-3-ZM-1 requires an equipment deficient evaluation form to be filled out and processed on all M&TE within 30 days from the date that it is suspect or fails recalibration. Forty (40) evaluation forms were observed as being greater than 14 days past the required 30 day requiremen ' The above violation will remain ope Preoperations Test Procedure Review During this inspection, the NRC inspectors reviewed the following preoperational test procedures:

1-DJ-P-05 125 VDC Class 1E Miscellaneous 1-SI-P-02 Safety Injection Accumulators 1-EW-P-04 ' Essential Cooling Water System Flow Balance 1-CC-P-01 Component Cooling Water System Train A 1-CC-P-02 Component Cooling Water System Train B 1-CC-P-03 Component Cooling Water System Train C

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1-CG-P-01 Electric Recombiner The listed preoperational test procedures were reviewed to ensure the '

contents were in accordance with the-FSAR, Regulatory Guide 1.68 and the

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The NRC inspectors found the instructions and procedures adequate. No violations or deviations were note :

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, Operations, Training, and Startup Testing Activities .

The NRC inspector. observed the following activities and found them being

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conducted by appropriate procedures or guidelines and acceptable.

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. Coordination and communication with the control room for testing activities and plant status, i . Clearance tagging for startup activities and plant maintenanc ,

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. Prerequisite testing on safety-related components such as component cooling equipment, emergency cooling equipment, high head and lo head safety injection compunents, 125V DC IE electrical' components and selected plant computer systems input '

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Flush activities for various reactor cooling system support system . Simulator preparation and debugging prior to commencing cold

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licensing simulator trainin . A good working relationship between startup, operations and plant-maintenance personne '

No violations or deviations were identifie . Fitness'for Duty The licensee has instituted a comprehensive Fitness for Duty program for all STP badged site employees, including those in the various Houston offices. This program includes a 100% base line scan of all employees by 4 a urine analysis and breathalyzer test for drugs and alcohol. A

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-laboratory has been established on site. In the event of a failed urine i analys.is, the test sample is rerun by another qualified lab technician and the sample is sent to an independent high tech laboratory off site for complete _ analysis. Those failing these tests are terminated and a work review is conducted to evaluate the past performance on the job. All prospective new hires are' screened prior to being hired. This program started testing December 29, 1985, and, to date, has had about a 1%

failure rate. All individuals who failed the test were terminated. After base lining all employees, retesting of employees will be on a random

' basis or if an employee displays suspect symptoms and abuse is suspecte The NRC inspector has observed the planning and implementation of'this program, operation of the analysis laboratory, and has reviewed selected packages on failed employees. This program was well publicized to i employees and counseling was made available to concerne.1 employees. This 1 program seems comprehensive, and acceptable.

i j No violations or deviations were identified.

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, Pressurizer Instrumentation Orifices The NRC inspector identified a skewed portion of the Unit 1, 3/4" pressurized level instrumentation line RC-6509-P-A2, between the pressurizer and valve RC-054B. There was no documentation available for review which identified the acceptable amount of bending in this lin The line was bent approximately 4 1/2 degrees down from perpendicular to the pressurizer. Since this pipe stub was supplied with the pressurizer by the Nuclear Steam Supply System (NSSS) vendo.r (Westinghouse) they ivere ,

asked for the fabrication tolerances. The stated tolerances were 1 degree with 31/2 degrees being acceptable based on previous NSSS analysis. Since this particular stub was a -41/2 degrees, the NSSS supplier will provide an engineering analysis to determine acceptabilit This is an unresolved item (498-8524-01) pending a review of NSSS supplied dat During review of the above condition, it was determined that the 3/8" orifices in four pressurizer level lines and one pressurizer sample line (all 3/4" lines) had not been installed as required by the NSSS vendor specifications. Fabrication and inspection was completed on all line The 3/8" orifices are the Class 1 - Class 2 boundary for the Reactor

' Coolant System (RC) and the absence of these orifices changes the location of the Class 1 boundary. The original NSSS prints included a note, which stipulated the 3/8" orifices were to be supplied by the Architect Engineer (AE). The NSSS note was subsequently combined with other notes and this requirement was dropped during Brown and Root (original A-E) and Bechtel (current A-E) drawing revisions. Instead of the NSSS Vendor requirements for the 3/8" orifices, the Bechtel print 2c-15-9-P-5051, detail F was referenced. This detail showed a difrerent nozzle-orifice connection than that which was supplied with the pressurizer. Construction isometrics taken from the currently approved A-E design documents showed piping going into a socket provided by the NSSS vendor with no mention of the orifice This is considered an apparent violation (498-8524-02 and 499-8521-01) of 10 CFR 50' Appendix B, Criterion III and STP Quality Assurance Plan (QAP)

Section 3.0, which requires measures be established for the identification and control of design interfaces and coordination among design organizatio Three one bynonconforming) conditions the licensee '.ere

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(two identified identified to the by theinNRC utility early the inspector and inspection period: (a) the skewed line on Unit 1 pressurizer, (b) the l five missing orifices on Unit 1 pressurizer, and (c) a bent 3/4" sample line on Unit 2 pressurizer. These items were clearly nonconforming and should have had a Nonconformance Report (NCR) written per STP Standard Site Procedure (SSP) 8, Revision 1. Hold tags should have been placed as specified by SSP-8, Section 5.8. From 1 to 3 weeks elapsed and no NCR or hold tags were processed. When questioned by the NRC inspector, the appropriate requirements were completed. This is an apparent violation (498-8524-03 and 499-8521-02) for failure to follow procedure i i

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- Exit Interview- -

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An' exit idterview was conducted on January 31, 1986,1with those personnel u: ,

denoted in paragraph 1 of this report.- During the exit interview, the NRC .

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-inspectors'sumarized.the scope and findings of this inspectio '

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