IR 05000445/1986009
| ML20212P350 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/28/1986 |
| From: | Barnes I, Kelley D, Will Smith, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212P344 | List: |
| References | |
| 50-445-86-09, 50-445-86-9, 50-446-86-07, 50-446-86-7, NUDOCS 8609030099 | |
| Download: ML20212P350 (9) | |
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APPENDIX
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'U.S.
NUCLEAR REGULATORY' COMMISSION
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REGION IV
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NRC Inspection Report:
50-445/86-09 Permits: CPPR-126
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50-446/86-07 CPPR-127
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Dockets:
50-445 Category: A2 50-446 Applicant:
Texas Utilities Electric Company (TUEC)
Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 & 2 Inspection At:
Glen Rose, Texas Inspection Conducted: April 1 through June 30, 1986 Inspectors:
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N D. L. Kelley, Senior 'Resicjdnt Reactor Date /
Inspector (SRRI), Region IV CPSES Group (paragraphs 2, 3, and 4)
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Trhrfr4 W.F. Smith,RisidentRea(tdrInspector(RRI)
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Region IV CP5ES Group (paragrapt.s 2 and 4)
Reviewed By:
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i R.L.Spessard,peputyDirector,Divisionof Date'
Inspection Programs, Office of Inspection and Enforcement Approved:
hwo 3* d ( /4"4 1. Barnes, Chief, Region IV CPSES Group Date 8609030099 860828 PDR ADOCK 05000445 G
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. Inspection Suimary..
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N'. Inspection Conducted:
pril'1'through June 30, 1986 (Report 50-445/86-09;
~50-446/86-07)
Areas Inspected:
Routine, unannounced inspection of:
(1) applicant actions on previous inspection findings, (2) design modification process issues, (3) plant tours, and (4) plant status.
Results: Within the three areas inspected, no violations or deviations were-identified.
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DETAILS 1.
Persons Contacted Applicant Personnel
- A. B. Scott, Vice President, Nuclear Operations
- M. R. Blevins, Maintenance Superintendent
- D. E. Deviney, Operations QA Supervisor
- R. A. Jones, Manager, Plant Operations D.W.Braswell,EngineeringSuperintendent(Operations)
R.. R. Wistrand, Operations Superintendent
- J. C. Smith, Operations Quality Assurance J. J. Allen, Operations Engineer
- M. J. Riggs, Operations Support Engineer
- R. W. Clark, Operations Support B. T. Lancaster, Administrative Superintendent C. L. Turner, Director, Nuclear Training R. Flores, Operations Engineer R. W. Haskovec Licensing
- C.'E. Scott, Startup Manager
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S. N. Franks, Special Project and Technical Support Lead D. Walling, Maintenance Engineer D.' Davis, Maintenance Engineering Supervisor
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- G. M. McGrath,: Special Project and Technical Support Lead T.-Jenkins, Operations Support Supervisor
- T. L.'Gosdin, Support Services R. Smith, Operations Support Engineer
B. B. Taylor, Instrument & Control Engineer
"L. G. ~Barnes,' TUGC0 Operations
- E. Alercon, TUGC0 Results Engineer
- C. H. Welch, TUGC0 QC Services Supervisor
- W. I. Melton, TUGCO, Administrative Assistant to the Vice President
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Nuclear Operations
- J. W. Andas,'TUGC0 Licensing R. D. Calder, Assistant Manager, Engineering (TNE)
- Denotes applicant representatives present during exit interview of July 2, 1986.
The NRC inspectors also interviewed other applicant employees during this inspection period.
2.
Applicant Actions on Previous Inspection Findings a.
(Closed) Violation (445/8502-V-05):
In January 1985, the RRI was conducting an inspection of the completed data package for test Procedure 1CP-PT-29-01, " Diesel Generator Auxiliary Systems." The inspector identified a failure to follew administrative requirements
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in that the-System Test Engineer.made unauthcrized= pen-and-ink
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changes to the procedure. Other examples of similar practices were cited..The applicant's response of October 10, 1985, was accepted by the NRC staff.on October 23, 1935. The'RRI reviewed the documentation of actions taken and verified that objective evidence existed showing that:
(1) a test deficiency report was initiated, dispositioned, approved by the Joint Test Group and appended to the completed test.
data package in.the Records Center, and (2) appropriate reinstruction of test personnel'had been implemented. This violation is closed, b.
(Closed) Violation (445/8445-V-02): During the months of November and December 1984, while the applicant was conducting a series of retests at hot plant conditions, the NRC resident inspectors identi-fied deficiencies in the generic procedures used by the Instrument andControl.(I&C) technicians. As a consequence of.using such a-generic procedure for filling a pressurizer. level instrument reference leg pipe while at hot plant conditions, errors were made resulting in fill tubing being blown off and the I&C technician receiving thennal burns on his arm from hot reactor coolant. The actions taken by the applicant included:
(1) evaluation and correction of all pressure, flow and level transmitters installed in the plant where the normal process fluid is at greater than 500 psig, 200 degrees F., or involves radiological controls, for proper labeling of valves to present a
.similar incident,-(2) revising the appropriate procedures to provide step-by-step instructions instead of the current generic prccedure format which allowed the I&C technicians to make too many decisions on their own, and (3) conducting training on the revised procedures.
When the RRI reviewed two of the revised procedures,-there were several deficiencies which were documented in NRC Inspection Report 50-445/85-14, Appendix C.
Since then, all of the applicable procedures have been satisfactorily rewritten and appear to contain; all of-the required attributes.. Training was conducted on May 9,
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1986,' as committed and was verified by RRI review of the training records. This. item is closed.
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(Closed) Open Item-(445/8308-0-01): During the Station Service Water c..
System walk down documented in NRC Inspection Report 50-445/83-01, n..
-the NRC inspectors noted that two piping manifolds for the service water pumps were.not shown on the system flow diagram.
It was also
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noted that the-flow diagram, 2323-M1-0234, sheet 1 of 2, Revision 9'
was not.the final as-built drawing, since the applicant had not at that time, performed the final as-built walkdown. The final as-built-drawing has been' issued. The SRRI reviewed the revision (2323-M1-0234, sheet 1 of 2, Revision'10) and noted that the missing manifolds had ~been added to the flow diagram. This item is closed.
3.'
De' sign Modification During this reporting period, the SRRI examined the applicants procedural controls of the design modification process. The procedures were
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inspected to determine if the regulatory requirements and applicants.
commitments had been met. The main areas examined were:
requirements for unreviewed safety issues, design review by the original designers or their qualified and designated equivalent, engineering document revision, design modification approval, design modification installation control, design modification revision control, post design testing, and design modification close out.
The TUGCo design modification process for implementation of the above requirements is Station Administrative Procedure STA-701, Revision 4, Station Modifications. STA-701 is a Station Operations Review Comittee (SORC) approved procedure which assigns responsibilities, authorities, and describes requirements.
The other organizations on site which have design modification responsibilities are the Results Engineering Group, Nuclear Operations Support Engir.eering, and TNE.
Each of these groups has a series of procedures addressing their role in the design modification process and to 1 direct their internal processes. These procedures are not SORC approved nor are they required to be.
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.The following is a listing of the procedures inspected by the SRRI and the assigned group:
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SORC: STA-701, Revision 4, Station Modifications.
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sults Engineering Group:
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l(1)' Reviews and Design Objectives EDA-201, Revision 2, dated June 25, 1985, Modification Request
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(2) EDd-203, Revision 0,datedJune 28, 1982, Design Verification (3) EDA-205, Revision 4, dated September 10, 1985, Modification Implementation (4) EDA-212, Revision 1, dated April 25, 1985, Review of Final Design Packages
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Operations Support Department:
(1) N0E-201, Revision 4, dated September 11, 1985, Design Modification Control (2) N0E-201-1, Revision 3, dated May 29, 1985, Design Modification Proposal (3) N0E-201-2, Revision 3, dated June 19, 1985, Design Modification Assessment l
(4) N0E-201-3, Revision 1, dated July 30, 1984, Design Development i
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6-(5) N0E-201-4, Revision 2, dated January 23, 1985, Design Verification (6) N0E-201-5, Revision 2, dated February 17, 1986, Station Drawing Change Control (7) N0E-201-6, Revision 0, dated November 30, 1984, Equipment and Engineering Specification Preparation and Review (8) N0E-201-7, Revision 1, dated October 1, 1985, Design Calculation Preparation and Review (9) N0E-201-8, Revision 1, dated March 17, 1986, Design Modification Closeout (10)N0E-201-11, Revision 1,datedOctober 10, 1985, Erection Specification Preparation and Review (11) N0E-201-12, Revision 2, dated March 3, 1986, Final Design Package (12) N0E-201-14, Revision 1, dated October 24, 1984, Emergency Modifications d.
TNE:
(1) TNE-DC-1, Revision 4, dated May 8, 1986, Design Control General
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Requirements (2).TNE-DC-2, Revision 3, dated July 9, 1985, Preparation of Safety
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(3.) ' TNE-DC-3, Revision 8, dated June 9,1986, Preparation and Review of Calculations
[4) TNE-DC-4, Revision 8, dated November 25, 1985, Preparation and Review of Specifications
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(5). TNE-DC-6, Revision 3, dated December 16, 1985, Equipment Classification Procedure (6) TNE-DC-7, Revision 17, dated June 9,1986, Preparation and Review of Design Drawings (7).TNE-DC-7-3, Revision 1, dated October 29, 1985, Preparation of
. Design Drawings by TSMD (8) THE-DC-8, Revision 5, dated October 25, 1984, Design Verification of. Engineering Documents
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(9) TNE-DC-8-1, Revision 9, dated September 5,1985, Engineering Review and Design. Verification of Field Design Changes
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(10)TNE-DC-11, Revision 4,datedAugust8,1985,Preparationand
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Review of Design Engineering Packages (11) TNE-DC-12, Revision 6, dated January 28, 1986, Preparation of Engineering Change Notices (ECN's)
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(12) TNE-DC-13, Revision 0, dated September 25, 1985, Review and
' Resolution of Field Change Requests (FCR)
(13)TNE-DC-17, Revision 3,datedMay 31, 1986, Preparation and Review of Design Basis Documents
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. (14) TNE-DC-21, Revision 4, dated May 8,1986, Preparation and Review of Field Design Changes (15) TNE-DC-24,-Revision'2, dated March 10, 1986, As-Built Package Preparation-1-
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(16) TNE-AD-4, Revision.10, dated June 9, 1986,. Control of Engineering Documents
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~(17)"TNE-AD-5, Revision 6,datedDecember 16, 1985,. Identification of Design Deficiencies and Errors-
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The design modification process as presently implemented was found by the
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NRC inspector to be very cumbersome and confusing, particularly so because
. design modificatio'is can be initiated procedurally from the construction
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and startup groups-in addition to the operations group.
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lThe process','when. initiated via STA-701, was tiered and allowed one group lto pass the modification request to the next group "up the ladder" as j-
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J either'the complexity increased or the need for more resources was
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Preliminary assessments made by the SRRI during the ~ process.
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review were: '(1). more-of the process detail needed to be added to STA-701
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(i.e., some of the requirements relative to assigned responsibility and
, e authority needed to'be moved from N0E-201 to STA-701; (2) field change
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requests; and -temporary modifications needed more restrictive controls;
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"(3) time limits.needed to be included-for drawing changes and procedure revisions and issue;!(4) EDA-205, Revision 4 states that prior to fuel-
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load' design change packages will be controlled by N0E-TP-85A-4-implemented.
- in accordance with STA-806. The words " prior _to fuel load" are inappropriate.since once the Operating License is issued and Technical
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provisions of'STA-701.
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While interviewing applicant personnel in conjunction with the design modification process, the SRRI learned that the process was being revised.
A corporate directive from the Executive Vice President, Nuclear
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Engineering and Operations was stated to be in final review prior to signature. The directive, one in a series of Nuclear Engineering and Operations directives (NE0s), was being issued which will alter the design modification process with respect to organizational responsibilities.
NE0 3.03 was indicated to have a requirement that all procedures must be revised and inplace by October 31, 1986. This NE0 was not available for review by the SRRI; therefore, pending review of NE0 3.03 and the revised implementing procedures, this item is considered unresolved (445/8609-U-01; 446/8607-U-01).
4.
Plant Tours During this reporting period, the SRRI and RRI conducted 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 was installed and where activities were in progress involving safety-related equipment. These areas were inspected to ensure that:
o Work in progress was being accomplished using approved procedures, o^
Special precautions for protection of equipment were implemented, and
additional cleanliness requirements were being adhered to for maintenance and welding activities, and
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.o-Installed safety-related equipment and components were being protected and maintained to prevent damage and deterioration.
Also during'these tours, the'SRRI and RRI reviewed the control room and shift' supervisor's log books.
Key items in the log review were:
o Plant status, o
Changes in plant status, o
Tests in progress, and o
Document!ation of problems which arise during operating shifts.
No violations or deviations were identified in this area of inspection.
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Plant Status as of June 30, 1986 a.
Unit No. 1 remains at 99% complete. Replacement of condenser tubing is in progress. A significant amount of pipe support rework is in progress and/or in the planning stage.
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Unit No. 2 is row 80% complete.
Preoperational testing of safety-related systems has not commenced; however, test procedures are being generate.
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Unresolved Items Unresolved items are matters for which more information is required in order.to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph 3.
7.
Exit Interview An exit interview was conduct'd July 2, 1986, with the applicant e
representatives identified in paragraph 1 of this appendix. During this interview, the operations SRRI summarized the scope and findings of the inspection. The applicant acknowledged the findings.
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