IR 05000445/1983008
| ML20023C418 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/28/1983 |
| From: | Kelley D, Mccrory S, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20023C408 | List: |
| References | |
| 50-445-83-08, 50-445-83-8, NUDOCS 8305170318 | |
| Download: ML20023C418 (11) | |
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APPENDIX B U. S. NUCLEAR REGULATORY C0fNISSIOF!
REGION IV
Report: 50-445/83-08 Docket: 50-445 Category: A2 Licensee: Texas Utilities Generating Company (TUGCO)
2001 Bryan Tower Dallas, Texas, 75201 Facility Name:
Comanche Peak, Unit 1 Inspection At: Comanche Peak, Unit 1 Inspection Conducted: fiarch 1-31, 1983
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Inspectors:
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///c, e/d 7/B a D. L. Kelley, Senior Rest ent I pector Datd
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S. L. ficCrory, Reactor Inspector "
Date Reactor Project Section A Approved:
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MJ g/g's T. F. Westerman, Chief Date
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l Reactor Project Section A l
Inspection Summary Inspection Conducted March 1-31, 1983 (Report 50-445/83-08)
Areas Inspected: Routine, announced inspection by the Senior Resident Inspector (Operations),includina: (1) Initial Startup Procedure Review; (2) Hot Functional Test; (3) Part 21: (4) Plant Tours; and (5) Plant Status. The inspection in-volved 170 inspector-hours by two NRC inspectors.
Results: Within the five areas inspected, one violation was identified.
(Failure l
to Review Procedure Change, paragraph 3).
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Details
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1.
Persons Contacted
- J. T. Merritt, Startup Manager
- J. C. Kuykendall, Manager, Nuclear Operations R. E. Camp, Lead Startup Engineer
- R. A. Jones, Manager, Plant Operations l
R. B. Seidel, Operations Superintendant
- T. L. Gosdin, TUGC0 Public Information Coordinator C. Killough, TUGC0 Operations Quality Assurance i
The Senior Resident Reactor Inspector (SRRI) also interviewed other licensee employees during the inspectica period.
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2.
Initial Startup Test Procedure Review (Isg)
The NRC inspectors reviewed twelve draft initial startup test procedures.
Comments were made where appropriate. The procedures will be reviewed in j
their final form after approval by the station operations review committee
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(SORC). Ilhen the preoperational tests are performed, a brief review will j
be conducted of the latest revision to note any changes that may affect the test results.
i The procedures are reviewed with specific emphasis on the following:
a.
Management review.
b.
Format clearly defines testing to be performed.
c.
Test objectives are clearly stated.
d.
Prerequisites are identified.
e.
Special conditions (if any) are specified.
f.
Acceptance criteria are identified and requirements are specified for comparison of results with the acceptance criteria.
Source of acceptance criterion is identified.
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h.
Initial test conditions are specified.
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Reference to appropriate FSAR sections, drawings, specifications, and l
codes are included, l
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Reactor operating mode and applicable Technical Specifications are identified.
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Step-by-step instructions of sufficient detail are included to ensure that conduct of the test will result in valid conclusions.
1.
Provisions of documenting that required steps have been performed and space for recording data are included.
m.
Temporary circuit changes, installation of jumpers, and restoration
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of circuits after testing are properly documented, n.
Technical Specification "Special Testing Exceptions" are listed.
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Independent verification of critical steps or parameters is addressed.
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During this reporting period, the following draft procedures were reviewed and returned with the following comments except where noted.
ISU-006A RCS and Secondary Coolant Chemistry Connents: Limitation 7.1.2.3 - A value cannot decrease by a
+ or - amount, but it can change, vary or deviate by a + or -
amount.
Procedural Section 9 does not contain prerequisite verifica-tion steps as do most other ISU's.
The prerequisite to have test equipment specified in Table 11.4.2 appears only in Part 8.1 which applies only to
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prefuel load.
It is apparent that this equipment is also used in post fuel load and power escalation phases.
In Prerequisite 8.1.5, what is meant by "... in good work-ing order."? If calibration requirements apply to any piece of test equipment, this would be indicated on the equipment table with entries to indicate the current state of calibra-
l tion.
Step 9.3.7 is incomplete.
ISU-020A Startup Adjustments of Reactor Control Systems j
i Comments: None ISU-203A Automatic Reactor Control System Test Comments: The steps following 9.1.2.2 and 9.2.2.2, respec-tively, are incorrect.
The note following steps 9.1.2.2 and
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9.2.2.2 states, "The following step is a negative tempera-ture (T avg) deviation." The subsequent step calls for out-rod motion which creates a positive tamperature (T avg)
deviation. The step should call for in-rod motion to estab-lish a deviation of -400 F to -500 F.
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ISU-204A Operational Alignment of Nuclear Instrumentation Comments: None ISU-205A Dynamic Automatic Steam Dump control Comments:
The intent of Prerequisites 8.1.11 and 8.2.11, and Steps 9.1.15, 9.1.18, 9.2.22, 9.2.26 and 9.2.30 is un-clear. What is to be filled in on Data Sheets 11.1.1.1 and l
11.1.2.1 prior to test start, and what, if anything, will be recorded during the conduct of the test? If recording is required during testing, the procedural steps do not direct that data be recorded but imply that it has been prtrecorded and provides the intermediate settings to be used.
ISU-207A Steam Generator Level Control Test
Comments:
None ISU-208A Radiation Survey Tests Comments:
None ISU-209A Area Radiation Monitoring System Comments:
None ISU-228A Pressure and Level Control System Performance Test Comments:
None ISU-229A Main Steam and MSR Performance Comments:
Each major test phase requires a system restor-i ation at the completion of the phase.
However, the initial
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test lineup and instrument hookup is the same for each phase. As written, the procedure does not allow progress-ing directly from one phase to the next without first disconnecting and then reconnecting the test equipment. An
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l applicability clause may be appropriate to allow progressing i
from one phase to the next without disturbing the test equip-(
ment lineup.
ISU-230A Condensate and Feedwater System Performance Test
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Coments:
Step 9.1.3.1 incorrectly lists temperature in-strument 1-TI-2220 as the sensing point for heater drain pumps.
Step 9.1.3.2 lists the correct instruments.
ISU-232A PSEUD 0 Rod Ejection Test Coments:
None No violations cr deviations were identified during this review. (8308-03)
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3.
Hot Functional Test The licensee authorized performance of the Hot Functional Test (HFT)
sequence procedure (PT-55-02, Rev. 2) on February 20, 1983.
The licensee completed filling and venting and established solid water pressure control on March 2, 1983.
The NRC inspector has been monitoring the performance of the HFT since its start.
The plant conditions as of the close of this reporting period (March 31, 1983)was:
0 F RCS Temperature - 557 RCS Pressure - 2235 psig (bubble in the pressurizer)
4 - Reactor Coolant Pumps Running Steam Dump System in pressure control mode for RCS temperature
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control.
The HFT sequence procedure (PT-55-02, Rev. 2) lists the following tests f
that are to be performed at the temperatures and pressures specified by the various tests:
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PT-02-12 Bus Voltage and Load Survey PT-02-13 Power Transformer Load Test PT-02-14 480V Switchgear Transformer Load Test PT-22-01 Process Sampling AT-22-02 Secondary Sampling PT-22-03 Post-Accident Sampling System AT-28-01 Feedwater System PT-34-01 Main Steam Isolation Valves
PT-34-02 Steam Generator Safety and Relief Valves i
AT-34-03 Steam Dump Control AT-34-05 Steam Generator Narrow Range Level Verification PT-37-03 Auxiliary Feedwater Turbine-driven Pump AT-44-02 Steam Generator Blowdown Hot Functional PT-45-06 Containment and Pump Room Coolers PT-49-02 Sealwater and Letdown Flow PT-49-05 Boron Thermal Regeneration AT-54-01 Gland Steam PT-55-03 Pressurizer Relief Valves PT-55-05 Pressurizer Level Control PT-55-06 Pressurizer Spray and Heaters PT-55-09 Reactor Coolant Pumps PT-55-10 Pressurizer Pressure Control PT-55-11 Thermal Expansion PT-57-09 Safety Injection Check Valves PT-58-02 Residual Heat Removal at Hot Functionals AT-62-05 Turbine Roll PT-74-02 Incore Thermocouple and RTD Cross Calibration
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PT-91-01 Loose Parts ibnitoring
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The NRC inspectors are periodically witnessing these tests to verify the following:
a.
Procedures in use are approved and being followed.
b.
Changes to procedures are made and approved in accordance with the procedures controlling change.
c.
There are an adequate number of personnel assigned to perfonn the test.
d.
There is adequate coordination between members of the test group.
e.
Necessary support systems are operational to conduct the pre-scribed tests.
f.
That the test procedures, operation of equipment and results achieved, approximate the operating characteristics and data that would result if the plant were operating with fuel in the reactor vessel and at normal operating parameters.
Several problem areas have been encountered. The major areas are:
a.
E.'ratic behavior of RCP seal flows b.
Thermal expansion c.
Letdown orifice size These items are presently being evaluated by the licensee.
The licensee is using the station operating and initial operating proce-dures to perform steps in conjunction with the preoperational test
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procedures, such as valve lineups and equipment sequence operation.
This performs two major functions.
First, to give the necessary detail i
to perfonn specific preoperational test functions by referencing plant procedures and to verify that the plant procedures are valid. Where this cannot be done using a plant procedure or precperational procedure due to unforeseen conditions, procedure changes are made.
The methods available are to change the preoperational test procedure using CP-SAP-12, Rev. 2, " Deviations To Test Instructions / Procedures," or STA-205, Pev. O, " Temporary Changes to Procedures" (i.e., plant procedures).
On March 7,1983, during a review of the logs and procedures used to draw a bubble in the pressurizer on the previous day, the VRC inspector noted ten steps of IPO-001A, Rev. 0, " Plant Startup From Cold Shutdown To Hot Standby," had been changed. Further review revealed the two changes had been accomplished using the appropriate change procedure but the remain-ing eight had not.
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These changes could have been made to IP0-001A to make the steps appli-cable to the functions being performed using STA-205, Rev. O.
Temporary changes to procedures, or the changes could have been made to PT-55-02, Rev. 2, " Hot Functional Test Sequence" using CP-SAP-12, Rev. 2, " Deviation To Test Instructions / Procedures," to include the steps necessary to per-form the functions. However, neither of these options were used, therefore the required reviews of the changes were not perfonned. This is considered a violation of Appendix B to 10 CFR 50.
(8308-01)
4.
Part 21 Followup The licensee has received a 10 CFR 21 report from Westinghouse Electric Corporation concerning reactor trip circuit breakers, type DB-50. The NRC inspector will review the licensees response to this item.
(8308-02)
S.
Plant Tours During this reporting period, the SRRI conducted several inspection tours of Unit 1.
In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment is installed and where activities were in progress involving safety-related equipment.
These areas were inspected to ensure that:
a.
Work in progress was being accomplished using approved procedures.
b.
Special precautions for protection of equipment was implemented, where required, and additional cleanliness requirements were being
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l adhered to, where required, fcr maintenance, flushing and welding activities.
c.
Installed safety-related equipment and components were being protected and maintained to prevent damage and deterioration.
Also during these tours, the NRC inspector reviewed the control room and shift supervisors' log books.
Key items noted in the log review were:
a.
Plant status b.
Changes in plant status l
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Tests in progress l
d.
Documentation of problems which arise during operating shifts l
No violations or deviations were identified.
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6.
Plant Status The following is a status of TUGC0 manning levels for operations and plant testing activities as of thrch 31, 1983:
a.
Operations Manning Status Authorized Personnel Level (including maintenance, operations, administration, quality assurance, and engineering) - 473 Number Presently Onboard 412 b.
Plant Testing Status Total Number of Preoperational Tests - 141 Number of Preoperational Tasts Through Draft - 139 Number of Preoperational lest Approved (JTG) - 128 Total Number of Acceptance Tests - 48 Number of Acceptance Test Through Draft - 47 Number of Acceptance Test Approved - 46 Test Completion Status
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Preoperational Tests - 52 Acceptance Tests - 33 No violations or deviations were identified.
7.
Exit Interview An exit interview was conducted thrch 31, 1983, with licensee representa-tives (identified in paragraph 1).
During this interview, the SRRI
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reviewed the scope and discussed the inspection findings.
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