IR 05000445/1988052

Insp Repts 50-445/88-52 & 50-446/88-48 on 880707-0802.No Violations Noted.Major Areas Inspected:Followup on Violations/Deviations,Followup on Applicant Identified Items & Preoperational Retest Program Activities

ML20151V334
Person / Time
Site:	Comanche Peak
Issue date:	08/15/1988
From:	Bitter S, Burris S, Joel Wiebe NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20151V327	List: IR 05000445/1988052 ML20151V322
References
50-445-88-52, 50-446-88-48, NUDOCS 8808220238
Download: ML20151V334 (12)

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U. S. NUCLEAR REGULATORY COMMISSIO OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/88-52 Permits: CPPR-126 50-446/88-48 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Date: Unit 1: Extension request submitted Unit 2: Extension request < submitte Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 l Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: July 7 through August 2, 1988 Inspector:

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ALk k M , /ea D. Bitter, Residdd't Inspector, 8hf

        'Datb Operations Inspector:    / P. Burris, Senior Resident Inspector, / D' ate Operations Reviewed by: bB. Wiebe, Lead Project,
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Inspector

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        /Date 8808220238 880815 PDR
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Q ADOCK 05000445 1 PDC '

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Inspection summary Inspection Conducted 1 July 7 through August 2, 1988 (Report , 50-445/88-52; 50-446/88-48) Areas Inspected: Unannounced res.', dent safety inspection of follow-up on violations / deviations; follow-up on aoplicant identified items, NRC Bulletins, pleoperational retest program activities, plant tours, safety evaluation report items; and follow-up on plant event Results: Within the areas inspected, no violations or deviations were identified. No significant strengths or weaknesses were identified. Unit 1 Preoperational Retest Program ~ activities and programs are consistent with the current applicant's projected schedul t

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DETAILS ,

           ' Persons Contacted      <
  ~ * P. Baker, Licensing Compliance Manager, TU Electric
  -* L. Barker, Manager, Engineering Assurance,~TU Electrici
  *M. R. Blevins,. Manager, Technical Support, TU Electric
  *W. J. Cahill, Consultant,.TU-Electric:       .
  *J. Conly, RAPE-Licensing,'SWEC   -
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  *W. G. Counsil, Executive Vice President, TU Electric I
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  *J. .Crnich, Project General Manager,:Ebasco-     .
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  *G. G. Davis, Nuclear' Operations Inspection-Report. Item Coordinator, TU Electric
  *J. Donahue, Operations Manager, TU Electric'     ,.
  *D. E. Deviney, Deputy Director,LQuality Assurance (QA),      .
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TU Electric f

  *S. Frantz, Attorney, Newman & Holtzinger, ' '

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  *M. D. Gaden, CPRT, IT Corporation ~       R
  *B. P. Garde, Attorney, CASE .

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  *W. G. Guldemond, Executive Assistant, TU' Electric     .
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  *P. E. Halstead, Manager, Quality Control.(QC),~TU~ Electric     -l
  *T. L. Heatherlyi Licensing Compliance Engineer,      ,

TU Electric

  * Jenkins, Manager, Mechanical Engineering,.TU Electric
  * Lowe, Director of Engineering, TU Electri !
  * Martin, Manager, Ebasco      !
  * Matthews, Chief. Inspector, State of Texas
  * McAfee, Manager, QA, TU Electric     ,
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  * Muffett, Manager of Civil Engineering, TU. Electric
  *E. Ottney, Representative, CASE       i
  *S. Palmer, Project Manager,.TU Electric
  *D. M. Reynerson, Director of Construction,'TU. Electric
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  *A. B.-Scott, Vice President, Nuclear Ooerations, TU-Electric
  *C. E. Scott, Manager, Startup, TU Electric-
  *J. S. Smith, Plant Operations Staff,- TU Electric-      .,
  *S. L. Stamm, Project Engineering Manager, SWEC      l
  *J. F. Streeter, Director, QA, TU. Electric i=   *C. L. Terry, Unit l_ Project Manager,'TU Electric      *
  *T. G. Tyler, Director of Projects, TU Electric     _

*B. Walker, Senior Inspection Specialist,' Texas Department of-Labor and Standards I *K. C. Warapius, Project Director, Impell . ._ .

*J. R. Waters, Licensing Compliance Engineer, TU Electric

  *C. S. Weary, Engineering, E&C, TU Electric       !
  *D. R. Woodlan, Docket Licensing Manager, TU Electric      '

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. 4 The NRC inspector also interviewed other applicant employees during this inspection perio * Denotes personnel present c*. the August 2, 1988, exit
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intervie . Follow-up on Violations / Deviations (92702) (closed) Violation (445/8707-V-03; 446/8706-V-01): Failure to promptly report deficiencies within the Class 1E 6.9kV switchgear. This violation resulted from the applicant failing to promptly report a deficient 10 CFR Part 50.55(e), condition identified during a previous inspection (445/8703-U-01; 446/8703-U-01). The NRC found that the Class 1E 6.9kV switchgear vendor (Brown-Boveri) had. notified the applicant of several deficiencies in 6.9kv'switchgear. However, over four months had elapsed before the applicant notified the NRC of the reportable deficiency. Subsequently, the unresolved item was escalated to a violatio In response to the Notice of Violation (NRC Inspection Report 50-445/87-07; 50-446/87-06), the applicant determined that the cause of the violation was the failure of personnel to document, in a timely manner, the deficiencies involving the Class 1E switchgear in accordance with the provisions of 10 CFR 50.55(e).

The applicant committed tx) taking the following corrective actions:

 . Documenting the deficiencies by issuing Corrective Action Report (CAR) 87-06 . Revise the program for identification and evaluation of potentially reportable conditions by revising or generating the following procedures:

NEO-9.01 Evaluation and Reporting of Adverse Conditions Under 10 CFR 21 and 10 CFR 50.55(e).

EC-9.01 Evaluation and Reporting of Adverse Conditions Under 10 CFR 21 and 10 CFR 50.55(e). i ECE-9.01 Evaluating Adverse Conditions for Effect on Plant Operations, Significance, and Reportabilit . Reporting the Class 1E switchgear deficiencies, pursuant to 10 CFR 50.55(e), via SDAR CP-87-0 . . .

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 . Issuing a directive to all engineering and construction organizations concerning the identification of possible 10 CFR 50.55(e)

condition . Ensuring (for deficiencies remaining open after July 25, 1987) that potentially reportable items are immediately reviewed by either CFE Engineering Assurance Regulatory Compliance personnel or by shift supervisor . Establishing (for deficiencies open prior to July 25, 1987) a program to evaluate deficiencies for reportability pursuant to 10 CFR 50.55(e). , The NRC inspector reviewed these corrective actions and noted no discrepancie Therefore, this violation'is close . Follow-up on Applicant Identified I,tems (92701) (Closed) SDAR Cp-82-07: "Defective Governor Drive Couplings." On August 18, 1982, the applicant received notification from Transamerica Delaval, Inc. (TDI) of a defect in the governor drive coupling on TDI diesel generator Failure of governor drive couplings to perform their safety function could occur as a result of the use of isoprene material which could deteriorate and ultimately fail when subjected to high temperature and an oil atmosphere found in the engine gear case. The applicant obtained the necessary replacement parts and implemented the appropriate work authorizations. The applicant completed the necessary changes to ensure reliability of the diesel generators.- The inspectors reviewed the following documentation to verify that all corrective actions have been completed:

 . Construction operator Traveler Z-803 and Z-80 . Woodard Bulletin 37708 . Nonconformance Report (NCR) M 82-01230 . Instruction Manual for Enterprise Engine The defective governor drive couplings were replaced and accepted on November 15, 1982. This item is considered close (Closed) SDAR CP-86-27: "Component Cooling Water System (CCWS) Radiation Detectors." In 1986, Gibbs and Hill

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 (G&H) expressed the concern that the radiation safety menitors in the CCWS-are required to detect radioactivity, but were not classified as nuclear safety relate In response, the applicant evaluated this concern and determined that the CCWS radiation monitors perform no safety function. Any leak in a component served by-the CCWS would be detected by the Class lE instrumentation in the CCWS surge tank. Furthermore, the consequences of any rupture in the CCWS are small when compared to the limits specified by 10.CFR 100'and are bounded by analyses in the FSAR. Therefore, the applicant has determined that this issue is not reportable under the provisions of 10 CFR 50.55(e).

The NRC inspector reviewed the applicant's evaluatio No discrepancits were noted. Tnerefore,' this SDAR is close . NRC Bulletins (92701) (Closed) IEB 77-07: "Electrical Penetrations." This bulletin was issued when it was identified that problems associated with epoxi' seal dry nitrogen type electric penetration assemblies (EPAs) caused erratic control of containment valves. Failure of the EPAs was due to electrical shorts between conductors within the EPA The applicant stated that they currently use Conax design EPAs which consist of a stainless steel sheath, polysulfone sealants, and Kapton insulated copper conductors. These penetrations use a dry nitrogen pressure as an environmental stabilizer. 'The applicant feels that the Conax design EPAs are not susceptible to similar failures outlined in the bulleti The inspectors notified the applicant that their response to this bulletin appears to be satisfactory; however, since the EPAs use Kapton insulated copper conductors, the inspectors will follow-up on the applicant's review of the industry identified failures of this type of insulation (50-445/8852-0-08). (Closed) IEB 79-10: "Requalification Training Program Statistics." This bulletin was issued to all licensees so that the NRC could perform evaluation of the operator 4 requalification training program. Due-to the status of CPSES at the time of issue, the applicant determined that this was a one. time request for jnformation and; therefore, no response would be necessary. The

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inspectors agree with this determihatio This bulletin-is considered close c. (Closed) IEB 83-01: "Failure of Westinghouse Reactor-Trip Breakers (DB-50)." Applicant's response to this builetin stipulated that since the failure of Westinghouse Breaker DB-50 was a specific equipment-problem and the breakers in use at the CPSES were a different type (DS-416UV), CPSES breakers should not experience a similar failure. The applicant reviewed the cause of the breaker (DB-50) failure and determined that their breakers (DS-416UV) would not undergo similar failures because of manufacturing differences and a breaker surveillance program which should identify any similar problems. Based on this review, the inspectors consider this item close d. (Open) IEB 85-03: "Motor-Operated Valve Failures." As requested by action Item e. of Bulletin 85-03,

"Motor-Operated Vaive Common Mode Failures During plant Transients Due to Improper Switch Settings," the applicant identified the selected safety-related valves, the valves' maximum differential pressures, and the applicant's program to assure valve operability in their letters dated May 14 and July 14, 1986. Review of these responses indicated the need for additional information ,

which was requested by an Office of Special PrcJects letter dated March 3, 198 Review of the applicant's April 8, 1988, response to'this request for additional information indicates that the applicant's selection of the applicable safety-related valves to be addressed and the valves' maximum differential pressures meets the requirements of the bulletin and that the program to assure valve operability requested by action Item a. of the bulletin-is now acceptabl The results of the inspections to verify proper implementation of this program and the review of the final response required by action Item f. of the bulletin will be addressed during a future inspection repor , e. (Closed) IEB 88-07: ' Power Oscillations In Boiling Water Reactors." Tnis bulletin was issued to all boiling water reactors and, therefore, is not applicable to CPSE For tracking purposes, this bulletin is considered close I

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. 8-5. preoperational Retest Program Activities (70301, 70302)

The inspectors reviewed the applicant's Unit l Preoperational-Retest Program activities to determine the status of program-completion. This inspection included review of-schedule status, procedure completion review, and discussions with start-up supervision and test personnel. . Retest procedure completion activittes show.that 2 procedures have been approved for use, 3 issued for approval, and 83 issued for comment out of a total of 146 procedures. The applicant continues to make progress towards completing their procedure review matri The inspectors obtained the latest approved schedule of Unit 1 retest program activities which shows that the majority of preoperational testing activities should commence in early August 198 Service Water System Discharge Canal Test During this inspection period, Stone and Webster Engineering Company (SWEC) questioned the capability of the service water discharge canal to handle the total discharge flow with all four of the service water pumps running. SWEC recommended adding retaining walls to the discharge canal from the discharge structure to the impoundment pon The applicant reviewed SWP:'s proposal and determined that before - authorizing this design change start-up should perform a four pump test run to determine if The canal could or could not contain the actual flow rat On August 2, 1988, the applicant uet up the service water system in accordance with Site operating Procedure 501A,

"Station Service Water System," and XCp-ME-1, Revision 6,
"Initial pump Operations," and ran all four pumps for an extended period without overflowing any portion of the discharge canal. Water flow levels were within the estimated prerun calculations and; therefore, the applicant hac determined that it appears there is no justification for placing retaining walls along the length ~of the discharge cana However, Start-up is recommending that the canal riprap be reworked to allow a smoother flow pattern, then
"use-as-is" with regard to canal channel heigh The inspectors will continue to review the status of Unit 1 Preoperational Retest Program activities during futurc .

inspection period l No violations or deviations were identified in the areas inspecte i

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. 9 1 Plant Tours (71302)    ;

The NRC inspectors conducted plant. tours during this inspection period. These tours provided coverage during normal, off-normal, and backshift working hours.During the tours, inspection activities included reviewing work documentation, witnessing ongoing work activities, observing and interviewing shift operations personnel, reviewing the status of control room construction work, reviewing the status of system and component completion, observing the status of Units 1 and 2 equipment lay up, observing housekeeping activities, and inspecting for general safety complianc To support these activities, NRC inspectors attended plan-of-the-day meetings and observed shift turnover briefing During the course of the tours and inspections, the NRC inspectors noted the following: Housekeeping activities are being adequately implemente Discussions with control room personnel, conducted-during all shifts, indicate that the personnel are fully aware of plant status, Operations personnel were alert and knowledgeable of plant mnd system condition No violations or deviations were identified in the areas inspecte . Safety Evaluation Report (SER) Items (92719) In the Safety Evaluation Report (SER) (NUREG-0797) dated July 1981, Section 5.4.1, the staff' required the technical specifications to include a' surface examination of the reactor coolant pump (RCP) flywheels as identified in paragraph c.4.b of Regulatory Guide 1.14. The inspector reviewed the second draft revision of the technical specifications for CPSES, Unit 1 and determined that surveillance Requiremenc 4.4.10 contains the '

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specified requirement. The inspector had no further questions concerning this issu In the SER (NUREG-0797) dated July 1981, Section 4.3.2, the staff required that the technical specifications limit the axial flux difference (AFD) band to plus or minus 5% until 3000 MWD /MTU burn-up. The NRC inspector reviewed the second draft version of the technical specifications for CPSES, Unit 1 and determined that the specified requirement is contained in Specification _ _ _ _

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. 10 3.2.1.a. The inspector had no further questions concerning this issu c. .In the SER (NUREG-0797)' dated July 1981, Section'4.4.1,
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method of-accommodating the thermal margin reduction caused by fuel. rod bow.. This requirement was stipulated' so that appropriate provisions.could be' incorporated into

 .the Technical Specifications. The staff also stated that any margin used to offset the reduction should be noted in the basis of-the Technical Specifications and the source and staff approval of this margin should be reference In the FSAR,.Section 4.4.2.2.5 (effective page dated ~

January 15, 1988), the applicant states that sufficient margin is available to completely offset the full and low flow departure from nucleate boiling ratio ~(DNBR) penalties associated'with fuel. rod bow. 'The NRC ' inspector concludes, therefore, that no additional provisions concerning this issue are necessary in the Technical Specifications. The NRC inspector notes, however, that although the source of the margin is . identified in the basis of the second draft version of the Technical Specifications for CPSES Unit 1,.the.NRC staff approval of the use of this margin is not referenced. This item is open pending resolution by the applicant (445/8852-0-02). In the SER (NUREG-0797) dated July 1981, Section 2.2.2, the pac staff states that the applicant has indicated that station personnel will patrol the area west of the safe-shutdown impoundment once a day to check ~for oil pipeline break In addition, the NRC staff states that the applicant has analyzed several pipeline breaks and will install three retaining ponds between the pipeline ' ar.d the safe-shutdown impoundmen The NRC inspector has posed several questions for response by.the applicant'to determine: (1) what mechanism is being used to ensure that station personnel patrol the area, and (2) that the l retaining ponds are able to function as described in the ' SER. This issue is considered open pending receipt of a this information from the applfcant (445/8852-0-03). ! In the SER (NUREG-0797) dated July 1981, Section 2.4.6, i the NRC staff expressed concern that piezometers show a higher ground water level than assumed for the design-basis groundwater level. Preliminary response from the applicant indicated that the principal source of the water was from conetruction activities end, to'a lesser degree, rainfall. The applicant expected that once construction is complete and the site is graded to l l

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. allow rainfall to run away from the site,' infiltration of water into the ground would be reduced to insignificant amounts. To ensure this, the applicant committed to a groundwater field monitoring program as soon as construction activities permit. The NRC inspector requested information from the applicant to aid'in the review of the groundwater field monitoring program, the results of the program, and the' applicant's conclusions regarding-indicated' groundwater level versus design-basis groundwater level. This issue is considered open pending receipt of this information from the applicant (445/8852-0-04). In the SER (NUREG-0797) dated July 1981, Section 1.4.8, the NRC staff required the applicant to commit to a program for monitoring sediment buildup in the safe-shutdown impoundment (SSI) and to define a procedure for removal of excess sediment. This item is open pending applicant's response to the NRC inspector's request for information concerning the above commitments (445/8852-0-05). In the SER (NUREG-0797) dated July 1981, Section 2.5.6.5, paragraph entitled "Rip Rap Construction," the NRC staff was concerned with the weathering of claystone that was observed during a site visit. The applicant committed to an annual inspection of the riprap for integrity. This item remains open pending applicant's response to the inspector's request for information concerning the above commitment (445/8852-0-06). In the SER (NUREG-0797) dated July 1981, Section 2.5.6.7, the NRC staff indicated that the applicant will perform an annual survey of the SSI surface alignment monument locations, annual measurements of the piezometric levels, and locate and monitor the settlement plates,-if necessary, at any time during the life of the SS In addition, the applicant committed to annually inspect the SSI visually, record instrumentation readings, evaluate the results of the inspection, and monitor for compliance with the design criteria in accordance with Regulatory Guide 1.127, Revision 1. This issue remains open pending applicant's response to the inspector's request for informatic.n to determine that the commitments arc being carried out as specified (445/8852-0-07).

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1 Follow-up on Plant Events (92700) On July 27, 1988, at approximately 9:30 a.m.,.the inspectors were informed that a contractor employee'had been electrocuted while working on heating ventilation air-conditioning (HVAC) ductwork. While moving an 85 pound piece of HVAC ductwork-above cable tray No. T120CB027 the employee apparently~ dropped

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the ductwork. When the ductwork fell,.it cut a 120-volt three-phase power cable (E0006956A) which supplied lighting transformer CPX-ELTRET-05. The inspectors noted that, although the rescue team responded quickly, they could not immediately remove the individual because the cable was still energized. The injured employee was carefully removed and transported to the local hospital, where he was pronounced dead on arrival. Power was dcenergized approximately 45 minutes after the event occurred. The inspectors notified the applicant that the NRC would review the circumstances surrounding the delay in securing all power within the cable tra This will be an open item pending review of all available information concerning operator ability to deenergize electrical equipment and cables (445/8852-0-01). Open Items open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, , and which involve some action on the part of the NRC or applicant or both. Open items disclosed during the inspection are discussed in paragraphs 4.a, 7.c, 7.d, 7.e, 7.f, 7.g, 7.h, and . Exit Meeting (30703) An exit meeting was conducted on August 2, 1988, with the applicant's representatives identified in paragraph 1 of this report. No written material was provided to the applicant by the inspectors during this reporting period. .The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio During this meeting, the NRC inspectors summarized the scope and findings of the inspection, i

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