IR 05000445/1984045

Corrected Pages 14-17 of Insp Rept 50-445/84-45,correcting Rept Details in Section 6 Re Applicant Action on Previous Insp Findings (Items 6.a(3),b,c & D)

ML20135H691
Person / Time
Site:	Comanche Peak
Issue date:	09/18/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135H685	List: IR 05000445/1984045 ML20135H684
References
50-445-84-45, NUDOCS 8509240133
Download: ML20135H691 (4)

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14 (Closed) Open Item 445/8415-02: Minor discrepancies found during NRC inspection of station administrative procedures. During a previous inspection (445/84-15) of station administrative procedures, the RRI found several minor discrepancies and made some suggestions to

.. preclude future problems. The applicant took action on those items that the applicant considered justification for implementing a procedure chang For example:

(1) STA-401, " Station Operation Review Committee," Revision 5, Section 4.4 did not fully implement the responsibilities of the committee as stated in the CPSES Unit 1 Technical Specifications (final draft). This was corrected in Revision 8 of STA-40 (2) STA-203, " Control of Station Manuals," Revision 7, Section 4. required a notification memo to be sent to each onsite holder of controlled station manuals to alert recipients of a revision or new procedure. This was not being done for holders of the manual who incorporate their own changes because they sign a receipt for the changes or new procedures anyway. Revision 9 clarified this such that the applicant is in compliance with the procedur (3) STA-307, " Forms Control," Revision.2, allowed minor changes to forms without revising the parent procedure containing a sample of the form as an attachment. However, instead of changing the revision number of the form itself, the office services staff misinterpreted Section 4.2.6 of STA-307 and changed the revision of the parent procedure attachment page, which caused a conflict with the rest of .the parent procedure pages. This was corrected by the applicant and STA-307 was revised to preclude misinterpretatio This item is close (Closed) Deviation 445/8415-01: Failure of the applicant to use SORC

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approved instructions to perform work on the emergency diesel generators.. The CPSES FSAR commits to Regulatory Guide (RG) 1.22, Revision 2, February 1978 with no exceptions. RG 1.33 and ANSI N18.7-1976 to which it refers,' requires maintenance to be performed using procedures / instructions receiving the'same review and approval as operating instructions, i.e., review and approval by the 50R During two previou's inspections (50-445/84-07 and 50-445/84-15), the NRC inspectors noted that the applicant had defined " instructions" as procedures which do not require SORC approval, and had issued

" instructions" to perform work on safety-related equipment such as 8509240133 850918 PDR ADOCK 05000445 G .PDR

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the emergency diesel generator (EDG). The apparent basis was that EDG work performed by the maintenance department had no significant impact on other departments, and/or was work unique to the maintenance department. Since the above NRC inspections, the issue has been resolved as evidenced in Station Administrative Procedure STA-707, " Safety Evaluations," (Revision 2), STA-202, " Preparation, Review, Approval, and Revision of Station Procedures" (Revision 10),

and the final draft of the CPSES Unit 1 Technical Specifications (TS). In essence, all safety-related procedures and instructions will receive a SORC review by virtue of the requirement that the S0RC review the related safety evaluations, as stated in the TS and STA-401, which both list the responsibilities of the 50R This deviation is close (Closed) Violation 445/8421-02: Failure of preoperational test procedures to provide adequate prerequisites. During a previous inspection (445/84-21), the RRI noted that during conduct of preoperational test ICP-PT-29-02,RT1, " Diesel Generator (DG) Control Circuit Functional and Start Test" the DG barring device was connected to a portable air compressor instead of the Service Air System. There was no prerequisite step in the test procedure to a provide either temporary or permanent air for the barring device, yet it needed air to be tested. Also, during testing of the Service Water System in accordance with ICP-PT-04-01, RT 1. " Station Service Water (SSW)," a Barton D/P gage did not' function due to air bindin There was no prerequisite in the test procedure to ensure the gage was recently filled and vented to assure accurate test data, nor did -

the Startup Administrative Procedures for writing the test require it. This was a potentially generic problem. The applicant has since -

revised CP-SAP-7, " Format and Content of Test Instruction / Procedures" to require the appropriate prerequisites. Each organization responsible for review of preoperational test procedures has been instructed to ensure that test prerequisites receive a comprehensive review to ensure system readiness and correct component configuration to assure validity of the test result This item is close . Plant Tours During this reporting period, the SRRI and RRI conducted several inspection tours of Unit In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment was installed and where activities were in progress involving safety-related equipment. These areas were inspected to ensure that:

Work in progress was being accomplished using approved procedure .)

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Special precautions for protection of equipment were implemented, and additional cleanliness requirements were being adhered-to for maintenance, flushing, and welding activitie *

Installed safety-related equipment and components were being protected and maintained to prevent damage and deterioratio Also during these tours, the SRRI and RRI reviewed the control room and shift supervisors' log books. Key items in the log review were:

plant status-

changes in plant status

tests.in progress

documentation of problems which arise during operating shifts

.No. deviations or violations were foun '8 . Plant Status as-of December 31, 1984 The applicant was at the end of the Thermal Expansion Test sequence and. making preparations to roll the main turbine-generator. Details of the testing sequence and problems encountered are discussed in paragraph 2 of this repor Unit No. 1 is 99% complete with 403 of 422 areas and 323 and 332 subsystems turned over to operations custody. " Custody" means having ininediate authority and responsibility for operational control of

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system or equipmen The applicant has accepted 260 of'332. subsystems for final

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acceptanc Of the 199 preoperational tests, one is not yet completed on field

. testing, and 21 are pending review and approval of completed dat Eighteen are pending NRC completed data inspection The following items related to NRC resident operations office findings are open pending applicant action and NRC followup inspection to confirm completion of closure:

Violations 10 Deviations 0 Open items 100 Unresolved' 7 Total 117

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Action is underway to complete these items. . Closure will be documented in future inspection. report . Unit No. 2 is 65% complete. The preoperation<.1 test program on

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. systems associated with NRC inspections.has-not yet starte . Exit Interview

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! An exit interview was conducted January 4,1985, with applicant F representatives identified in paragraph 1. During this interview, the RRI and Mr. D. M. Hunnicutt of the Region IV NRC office reviewed the scope and discussed the inspection findings. The applicant acknowledged the

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