IR 05000445/1989052
| ML20246A940 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/17/1989 |
| From: | Latta R, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246A938 | List: |
| References | |
| 50-445-89-52, 50-446-89-52, EA-86-009, EA-86-9, IEB-85-003, IEB-85-3, NUDOCS 8908230191 | |
| Download: ML20246A940 (16) | |
Text
,,
.,
__
- _ _ _ _ _ _ _
. - - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _
.
...
,
.
.
,
U..S.
NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC' Inspection Report:
50-445/89-52 Permits: CPPR-126 E0-446/89-52 CPPR-127 Dockets: 50-445 Construction Permit 50-446 Expiration Dates:
'
Unit 1: August 1, 1991 Unit 2: August 1, 1992 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 & 2 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
July 6 through August 1, 1989 Inspector-2 4 a a:A E- >
S-I'7-i a
R. M. Latta, Resident Inspector Date I
(Paragraphs.3, 4, 5, 6, and 7)
Consultants:
W.
Richins - Parameter (paragraphs 2 and 6)
J. L. Taylor - Parameter (paragraphs 2, 3, 4, and 5)
C - ! 7-6 Reviewed.by:
E444IJLt/
H. H. Livermore, Lead Senior Inspector Date
..
8908230191 e9o3yg DR ADOCK 05000445 PDC a
_
_ _ _ _ - _ _ _ _ - _
__
__
.-
't l'
..s
..
!-
U
.;
..
~ Inspection Summary:
'
Inspection Conducted:
July 6 through August 1, 1989 (Report 50-445/89-52; 50-446/89-52)
Areas Inspected: Unannounced, resident safety inspection of
. applicant's actions on previous inspection findings; follow-up on violations / deviations; action on 10 CFR 50.55(e) deficiencies.
L identified by the applicant; plant tours; and safety-related mechanical components.
l Results:
Within the areas inspected, no significant strengths or
. weaknesses were identified; however, two open items were identified regarding check valve' reassembly and testing procedural revisions (paragraph 6).
During the inspection period, no violation, or
' deviation was identified.
Two management meetings were held in which significant safety matters were discussed (paragraph 7).
_-_- -
...
e
.
..
.
.
DETAILS 1.
Persons Contacted
- J.
L. Barker, Manager, ISEG, TU Electric
- J. W. Beck, Vice President, Nuclear Engineering, TU Electric
- O.
Bhatty, Issus Interface Coordinator, TU Electric
- M.
R. Blevins, Manager of Nuclear Operations Support, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- H.
M.
Carmichael, Senior QA Program Manager, CECO
- D.
J. Chamberlain, Licensing Lead Engineer, Unit 2, CECO
- J. T. Conly, APE-Licensing, Stone and Webster Engineering Corporation (SWEC)
- W.
G.
Counsil, Vice Chairman, Nuclear, TU Electric
- B.
S. Dacko, Licensing Engineer, TU Electric
- D.
L. Davis,-Nuclear Operations, Results Engineer Manager, TU Electric
- R.
J. Daly, Manager, Startup, TU Electric
' *G.
G. Davis,-Nuclear Operations Inspection Report Item Coordinator, TU Electric
- G.
L. Edgar, Attorney, Newman and Holtzinger
- D. M. Ehat, Consultant, TU Electric
- J.
C. Finneran, Jr., Manager, Civil Engineering, TU Electric
- C.
A. Fonseca, Deputy. Director, CECO
- B. P. Garde, Attorney, CASE
- J.
H. Greene, Site Licensing, TU Electric
- W.
G. Guldemond, Manager of Site Licensing, TU Electric
- P.
E. Halstead, QC Manager, TU Electric
- J.
C. Hicks, Licensing Compliance Manager, TU Electric
- C.
B. Hogg, Chief Manager, TU Electric
- R.
T. Jenkins, Manager, Mechanical Engineering, TU Electr!'.
- J.
J. Kelley, Manager, Plant Operations, TU Electric
- J.
J. LaMarca, Electrical Engineering Manager, TU Electric
- D. M. McAfee, Manager,HQA, TU Electric
- S.
G. McBee, NRC Interface, TU Electric
- W.
E. Nyer, Consultant, TU Electric
- G.
Ondriska, Startup, TU Electric
- E..F.
Ottney, Program Manager, CASE
- S.
S. Palmer, Project Manager, TU Electric
- P.
R. Raysircar, Deputy Director / Senior Engineer Manager, CECO
- D. M. Reynerson, Director of Construction, TU Electric
- A.
H. Saunders, Qurlity Surveillance, TU Electric
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
- J.
C. Smith, Plant Operations Staff, TU Electric
- J.
F. Streeter, Director, QA, TU Electric i
- C.
L. Terry, Unit 1 Project Manager, TU Electric
)
- R.
D. Walker, Manager of Nuclear Licensing, TU Electric
- J. R. Waters, Site Licensing Ennineer, TU Electric
- R.
G. Withrow, EA Systems Manager, TU Electric
- --
.,
s=
.
.:
..
..
<
The.NRC inspectors also interviewed other applicant employees during.this inspection period.
- Denotes personnel present:at the August 1, 1989, exit meeting.
>
2.
Applicant's Action on previous' Inspection Findings (92701)
a.
(Closed) Open-Item (445/8845-O-01):
Replacement of Unit 1 emergency diesel generator (EDG) wattmeters.
As
~
documented in the partial closure of Allegation OSp 84-A-0022 in NRC Inspection. Report 50-445/88-45; 50-446/88-41, this open item was identified to' track the replacement of the Unit 1.EDG wattmeters with qualified I
units.
The NRC inspector reviewed the associated documentation and verified that the meters had been replaced and calibrated.
The Unit 1 meters were replaced with the qualified meters from Unit 2.
New Unit 2 meters will be procured and installed at a.later date (Commitment 18163).
The NRC inspector requested additional information from the applicant to address the commitment-in
'
letter TXX-88294 which stated that the meters would be installed in Unit 1 prior to Unit 1 hot functional testing (HFT).
However, it was determined that the meters were actually installed after the test.
The applicant agreed to address this. issue which will be documented in a subsequent inspection report.
With the exception of the issue of failing to replace the_ Unit 1 l
wattmeters prior to HFT, the NRC inspector determined j
that the applicant's actions in the balance of'this item i
were acceptable.
This item is closed.
l l
b.
(closed) Open Item (445/8922-0-02):
This item addressed
,
two Ashcroft 0-5000 psig test gauges used for the
'
official and backup gauges during the reactor coolant
system (RCS) VT-2 Hydrostatic Test 5500 on April 24, I
1989.
both gauges (Tag Nos. IC-2779 and IC-2951) were
calibrated and adjusted as necessary'on April 19, 1989, l
prior to the-RCS VT-2 test.
The two gauges were found to l
be out-of-calibration during a post test calibration-j performed on April 23, 1989.
The NRC inspector requested j
information from the applicant regarding the validity of the RCS VT-2 test results, the root cause of the failure
,
of the test gauges, and planned corrective action.
!
i The applicant issued Deficiency Report (DR) p-89-00486 to i
address the out-of-calibration test gauges.
The DR was
dispositioned and closed concluding that the minimum test i
pressure conditions in accordance with ASME Section XI d
had been met.
Gauges IC-2951 and IC-2779 were found j
L
!
i i
i E ___ _
_
l
,.
. - - - -
-
- - - - - - - - - - - - - -
-
.l
.
.
.
.
.
during the post test calibration to be 30 psi and 20 psi
,
high, respectively.
The minimum gauge pressure required i
d by test 5500 was 2310 psig.
During the test, a gauge pressure of 2340 psig on both gauges was verified as being maintained.
This pressure, 30 psi higher than the minimum required pressure, compensated for the out-of-calibration condition.
The applicant issued Memorandum TIM-891727 from the I&C/M&TE calibration laboratory recommending that Aschroft pressure test gauges not be used in applications q
where pressure surges and/or water hammering may occur.
-
These conditions apparently can cause the needle pointer to spin on the gauge shaft.
TIM-891727 also states that the out-of-calibration conditions found, ".
..were
.
caused by rapid depressurization and could have been avoided by slowly depressurizing the gauges prior to disconnecting them from the system."
The applicant has ordered new Heise gauges to replace the Aschroft gauges for tests where the Aschroft gauges are not recommended per TIM-891727.
Gauge IC-2779 is still in use while Gauge IC-2951 has been removed from service.
The NRC inspector has reviewed documentation, procedures, purchase orders, and calibration test results regarding this issue.
The NRC inspector concluded that the minimum gauge pressure required by test 5500 was maintained and that the applicant adequately identified the cause of the gauge failures.
Use of the new gauges and/or requirements to slowly depressurize the gauges prior to disconnecting them from the system should reduce the potential for gauges failing post test calibration.
This
item is closed.
3.
Follow-up on Violations / Deviations (92702)
_
a.
(Closed) Violations (445/8604-V-13 and EA 86-09, Appendix B, Item I.B.1.b):
Electrical penetration assembly (EPA) junction box seals not installed.
This violation (which was similarly identified by both of the reference tracking numbers) involved junction boxes to which cables were routed from several EPAs which did not have the conductor entry conduit sealed as specified in the applicable installation drawing.
The NRC inspector reviewed the applicant's response to
this violation contained in TU Electric's letter TXX-6262
)
dated February 27, 1987, and determined that the i
requirements to provide seals as described in Detail B of
)
Drawing 2323-El-514, Revision 7, were implemented by Design Change Authorization (DCA) 10628.
The NRC i
i
c
._
-
_ _ - - _ _
v
,
.
..
.
inspector determined that when this DCA was incorporated into the subject drawing, the conduit seals were intended to be equipment seals; however, they were characterized as fire stops.
Furthermore, it was ascertained that the controls for the installation and verification of the seals were not developed due to programmatic inadequacies and the lack of interdisciplinary controls.
Subsequent to the identification ~of this violation, the applicant reviewed the design and function of the specific junction boxes and determined that for these applications the seals did not provide a safety-related function and that they were not required.
Correspondingly, the seals were reclassified as nonsafety-related and/or eliminated from the design.
The NRC' inspector reviewed the applicant's corrective actions as delineated in Nonconformance Reports (NCRs) 89-5133 and E86-101009 as well as DCAs 25656 and 10628.
These documents effectively revised the controlling drawings and eliminated the requirements for fire stop seals on the subject conduit seals.
The NRC inspector determined that the conduit seal configurations in question (inside containment near the EPAs) do not require fire stop seals and that the corrective actions taken by the applicant to revise the controlling design drawings were acceptable.
Additionally, the applicant's enhanced evaluation process for DCA review and drawing revision appear adequate to prevent reoccurrence of this violation.
This item is closed.
b.
(Closed) Violation (445/8730-V-06):
This violation was attributed to the presence of two capacitors in parallel across the coil of relay TD-4 in the emergency diesel starting circuit which were not shown on facility electrical drawings.
The applicant agreed with the
. violation and initially determined that the capacitors were vendor installed and had no apparent function.
However, subsequent testing determined that the capacitors were required for proper operation of the failure-to-start alarm circuit.
The applicant modified the circuitry drawing by DCA 61459 to show the current as-built condition and to install the circuitry in Unit'2.
The NRC inspector reviewed the violation closure package submitted by the applicant and determined that corrective action was acceptable; however, there was no follow-up letter to the NRC subsequent to original response TXX-88079 that addressed the latest corrective action steps taken.
The applicant agreed to address this concern by submitting a supplemental response to the violation.
This violation is closed.
)
.
.... _ _ _ _ _ _. - - - - - - - - - - - -.
- - - - - -.
)
- - _
r
-
p.
.
L
.
.
b
'
.
4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
,
a.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-86-24):
" Space and Motor Heaters.
The deficiency involved the use of unqualified motor operator switch compartment space and motor heaters connected to Class 1E circuits.
The applicant determined that the deficiency was nonreportable in that the 1E circuits that power the heaters are protected by current interrupting-or limiting. devices.
These devices, though not recognized by Regulatory Guide 1.75 as approved isolation-devices, are approved by IEEE-384 for use on control circuits.
Therefore, there was reasonable assurance that the 1E busses would not have been degraded had the heaters remained connected and experienced failure.
The NRC inspector concurred with the determination of nonreportability.
Additionally, the applicant had the heaters disconnected to ensure proper isolation.
The NRC inspector reviewed DCAs 57978 and 57979 which-deleted heaters and/or spared cables for approximately 200 Unit 1 components, and selected five of these components for work package review.
Work packages for equipment 1HV-4708, CPX-VAFNID-01, and 1HV-6076 contained either travelers, QC inspection reports, or startup work authorizations (SWAs) which documented completion of the work.
Documentation of work completion for CP1-VAAUSE-10 and ILCV-0112C was found in the applicable cable work packages EG113488 and EG121805, respectively.
Based on the above review, this construction deficiency is closed for Unit 1 only.
b.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-86-38):
" Traceability of 1E Pigtail Extensions." This deficiency involved failure to incorporate cable reduction splices and pigtail extensions into design drawings in order to assure proper inspection and traceability.
The NRC inspector reviewed Corrective Action Report 63, Revision 1; DCA 21912, Revision 2; and DCA 31435, Revision 0; as well as current changes to Electrical Specification ES-100.
These documents indicate that the deficiency was adequately addressed and corrected.
Additionally, Field Verification Method (FVM) EE-021 and 022 were performed as part of the post-construction hardware validation program (PCEVP) to evaluate and document reducing splices and pigtail extensions.
Additionally, related inspections for pigtail lengths were performed during the closecut of Violation 445/8518-V-01 as documented in NRC Inspection Report 50-445/89-04; 50-446/89-04.
Unit 2 field verification was initially scheduled to be implemented in the same manner as Unit 1, by March 1988,
_
_ _.
.
-
.
.
8
,
per letter TXX-6455 dated May 20, 1987.
However, final report letter TXX-88226 dated February 22, 1988, rescheduled Unit 2 efforts for completion prior to Unit 2 fuel load.
Therefore, this construction deficiency is closed for Unit 1 only.
c.
(Closed) Construction Deficiency (SDAR CP-87-60):
" Installation Configuration of ASCO Solenoid Valves":
As previously documented in NRC Inspection Report 50-445/89-07; 50-446/89-07, this condition involved the qualification of Automatic Switch Company (ASCO) solenoid-valves which had been inadvertently installed in harsh environmental areas without exhaust port elbows.
In particular, the definitive test data establishing the environmental qualification of these valves without exhaust elbows installed was not previously available.
On July 17, 1989, the applicant provided additional documentation by letter TXX-89349 supporting the nonreportability of this issue and providing supplemental information regarding the environmental qualification of these solenoid valves.
The NRC inspector reviewed the subject letter which addressed the qualification testing performed on the ASCO solenoid valves and performed inspections of the affected plant equipment.
As stated in the reference letter, the applicant established that during design basis earthquake (DBE) and post DBE simulation testing, the exhaust ports were connected to tubing which exhausted outside of the
- test chamber.
This test configuration was designed to monitor valve leakage.
As stated in ASCO report AQR-67368, Revision 0, the function of the exhaust port elbow is to preclude the entry of downward directed containment spray from entering the internals of the valve through the exhaust port during a loss of coolant accident.
As a result, the test did not establish an adequate basis for qualification of the ASCO solenoid valves without exhaust port elbows.
,
Subsequent analysis performed by the applicant revealed that the ASCO solenoid valves located inside containment would not have been affected by the absence of exhaust port elbows.
This determination was based, in part, on the design accident function of certain valves and to the sequenced operation prior to the initiation of containment spray for the remaining valves.
Additionally, for those valves located outside
!
!
containment in a potentially harsh environment, the applicant's documentation appeared to support the i
i contention that they were qualified for their intended l
function without exhaust port elbows.
,
__. a
,
,
f
.
.
..
9
,
Based on the above inspection activities, the NRC inspector concluded that the applicant's determination of nonreportability was acceptable.
d.
(Closed - Unit 1 only) Construction Deficiency (SDAR CP-87-98):
" Cable Raceway Fill Calculations -
Cable Outside Diameter."
This issue involved the use of nominal cable diameters instead of maximum cable diameters for calculating raceway fill.
The applicant determined that the deficiency was nonreportable. based primarily on use of parameters in the raceway percent fill calculations for the cable and raceway data system (CARDS) which allow for conservatism.
Therefore, the fact that some cable diameters are greater than the nominal values (but within specified tolerances; does not constitute a safety significant deficiency..
The NRC inspector reviewed cable cross sectional area calculation 16345/6-EE(s)-736 and a portion of CPSES-E-1038, Appendix B, related to CARDS design percent fill calculation and noted that some conservatism was included
'in the CARDS calculation by use of cable area multipliers greater than one and an allowance factor.
The applicant additionally issued DCA 60035 to revise cable diameter values to maximum instead of nominal and restrict certain cable types-to nonsafety use only.
The NRC inspector reviewed DCA 60035 and determined that it was adequate but noted that Revision 2 oE the DCA deleted Unit 2 CARDS validation.
Unit 2 CARDS validation is to occur once DR C-88-01310 is closed.
Based on the above, this construction deficiency is closed for Unit 1.
e.
(Closed) Construction Deficiency (SDAR CP-87-99):
" Cable Outside Didmeter Requirement."
The applicant reported that an evaluation of NCR CE-87-1357, Revision 1, revealed that approximately 100 reels of cable types W-065, W-165, W-265, and W-765 exceeded the maximum specified outside diameter (OD).
Further evaluation by the applicant resulted in a determination of nonreportability since the cable purchase specification
'
for OD was a nominal, not maximum, value.
The implications of greater diameter cables on cable weight and raceway fill were addressed in SDAR 87-98 which is discussed in paragraph 4.d of this report.
The NRC inspector concluded that the applicant's determination of nonreportability was acceptable; therefore, this construction deficiency is closed.
f.
(Closed) Construction Deficiency (SDAR CP-87-101):
" Class 1E Cable Arrangement."
This deficiency involved the routing of Class lE electrical circuits with multiple
conductor per phase feeders which may have provided the
'
potential to overheat.
As previously reported in NRC
!
< _ _ _ _ - _ -
-
l
(
. _ - -
--
_ _ ___ _
i
!.
.
.
,
Inspection Report 50-445/89-49; 50-446/89-49, the NRC inspector-questioned the fact that disposition of NCR 87-02304 and NCR 02305 regarding emergency diesel generator cables did not address the remaining cable qualified life.
The applicant revised the change verification checklists (CVC) for the NCRs to include a calculation of the accelerated aging of the cables due to
'
generator operation (to date).
The NRC inspector reviewed the CVCs and concluded that the aging effect was negligible (260 hour0.00301 days <br />0.0722 hours <br />4.298942e-4 weeks <br />9.893e-5 months <br /> reduction of 65 year qualified life).
Therefore, this construction deficiency is closed.
5.
-Plant Tours (25573, 35960, 42051C, 50073, 51053, 51055)
The NRC inspectors conducted routine plant tours during this
' inspection period which included evaluation of work in progress as well as completed work to determine if' activities involving safety-related electrical systems and components including electrical cable were being controlled and
' nce with regulatory requirements, accomplished in ac i
industry standarda, aLd applicant procedures.
In particular, the-NRC inspectors observed the troubleshooting tests of the auxiliary feedwater (AFW) system identified in plant incident report (PIR)89-202.
The PIR noted Borg-Warner check valve 1-AF-065 was rattling and flow indication was varying from 0 to 200 gpm on motor driven auxiliary feedwater pump (MDAFWP) 01 while it was not running.
At this time, MDAFWP 02 was running on recirculation to the condensate storage tank.
The troubleshooting progressed without incident with'various valve lineup changes made to observe the effects on the MDAFWP-01 flow meter and associated check valves.
As determined by the NRC inspector, site engineering personnel will analyze the test results to determine the cause of the apparent recirculation flow in the MDAFWP-01 piping.
No conclusions could be drawn from the observations of the troubleshooting; however, the NRC inspector will continue to follow this trouble shooting-evaluation and the results will be documented in a subsequent inspection report.
The NRC inspectors also observed motor operated valve analysis and test system (MOVATS) static testing of valve 8801B as part of IE Bur itln 8503 follow-up.
Test personnel appeared very knowledgeable of all aspects of the testing including valve torque switch adjustments and test equipment operation.
Further dynamic valve tests will be observed per TI-2525/73 and documented in future inspection reports.
Several fire watch logs were reviewed at different times during the inspection period and hourly updates were found to be current.
Additionally, the NRC inspector checked various
_
._
_ _ _ _ _ _ _
-
.
.
.
.
,
fire hose stations which appeared to be adequately maintained.
Cleanup efforts are continuing around the plant and no excessive wood or debris was noted.
6.
Safety-Related Components, Mechanical (50071, 50073)
on April 23, 1989, a misalignment of the turbine driven auxiliary feedwater pump discharge valves during hot functional. testing in combination with multiple failures of Borg-Warner check valves induced a backflow of high temperature water from the steam generators through AFW piping to the condensate storage tank.
This event, in combination with a similar event on May 5, 1989, caused paint on the AFW piping to discolor and blister.
In addition, at least one pipe support was damaged by thermal expansion.
The failure of the AFW Borg-Warner check valves to prevent reverse flow was extensively investigated by the applicant (see NRC Augmented Inspection Team report 50-445/89-30; 50-446/89-30).
The applicant's corrective action included a valve-specific bonnet elevation adjustment and a verification that the axial play in the disc-arm assembly is within a specified envelope.
All Borg-Warner check valves located in Unit 1.and Common areas will be physically examined / adjusted-and retested for reverse flow operability.
This report section documents the applicant's activities regarding this corrective action witnessed and inspected by NRC inspectors during this report-period.
Three check valves failed the reverse flow operability (back leakage) test following reassembly using the modified installation methods necessary for correct bonnet elevation adjustment per NCR 89-6637, Revision 4.
The valves (lAF-075, lAF-078, and 1AF-101) are Borg-Warner 4-inch pressure seal l
swing check valves.
Valve 1AF-101 initially leaked during this test, but did seat and hold backpressure after test personnel mechanically agitated the valve body.
Radiographic tests (RTs) were performed on the remaining two failed check valves.
The valve discs were contacting the seat ring at the top, but were lying slightly off the seat at the bottom of the valve.
I Forward flow was applied to the four check valves in'the motor j
driven AFW supply lines (valves lAF-075, lAF-101, lAF-083, and
'
1AF-093) to flush the valves and check for forward flow operability.
Valve 1AF-078 on the turbine driven AFW supply line could not be forward flow checked and flushed due to plant conditions.
The four motor driven AFW supply line check valves were tested
!
for reverse flow operability again following the forward flow
!
!
_ - - _
,
_
. - _
'
i v' u
~
.
.
.
--,'
flush.
Valve-1AF-075 continued to~ fail, valve 1AF-101 passed the test showing no further back leakage, and valves lAF-083 and 1AF-093. continued to pass the test.
With the NRC. inspector present, Borg-Warner check valves
'lAF-075 and'lAF-078 were then disassembled per NCR 89-8010, Revision 0, in an attempt to determine 1the root cause ofLthe backleakage.
The NCR required checking for:
(1) rotational
- misalignment, (2) mechanical-binding in the disk and hinge pin / clevis assemblies, and (3) lodged _ debris.
Both valves were found_.to have been installed with rotational. misalignment between the bonnet-disk' assembly and the seat.
The applicant personnel used the studs on the bonnet for reference ~and determined-that the valve bonnets wereimisaligned counter-clockwise with respect'to the valve body and associated piping.
This.was documented >in'NCR_ 89-8010, Revision 2.
The NRC inspegtor approximated.the amount of misalignment to-be_2 to 3 The~ valves were subsequently
.
reinstalled using the. studs to align the bonnet-disk assembly
. perpendicular to the center ~line of the valve body and match marks were inscribed for use during future reassembly.
The two valves.were then tested _for reverse flow operability and found satisfactory.
The NRC inspector witnessed the backleakage testing and exploratory disassembly, examined the valve internals, and reviewed the documentation and procedures associated with the seating problems with valves lAF-075 and 1AF-078.
The MRC inspector concluded that rotational misalignment was the probable root cause for the backleakage discovered after the valves were reinstalled with vertical adjustment of the retainer ring.
The applicant plans to modify the Borg-Warner check _ valve reassembly procedure to require more precise rotational alignment.
The NRC inspector questioned the adequacy of using the studs as a reference.
Specifically, is the location of the studs in relation to the disk and clevis a controlled feature?
The review of the modified reassembly procedures requiring more precise rotational alignment is an open' item (445/8952-0-01).
The reverse flow operability tests discussed above were performed using Procedure EGT-328A, Revision 0, " Reverse Flow Operability Testing for Auxiliary Feedwater Check Valves."
The NRC inspector witnessed the implementation of this procedure and concludad that the tests adequately determined the operability of the valves in the reverse flow direction.
The NRC inspector,.10 wever, did have the following concerns l
regarding the proceCure and the required documentation:
I-L
_
p
.
.
..
'
13.
,
Acceptance criteria were not defined.
.
'
The pressure of the test source (demineralized water) was
.
not recorded before or after opening the flow path.
The results of the tests (pass-fail) were not decumented
.
on the data. sheets.
The amount of backleakage was not documented either
.
quantitatively or qualitatively.
These concerns were communicated to the applicant test
. personnel.
The amount of backleakage, if present, will not be quantitatively measured but will be documented qualitatively in the test logs.
The ASME Section XI code only requires verification that the valves seat.
The applicant provided the NRC inspector with a draft copy of Procedure EGT-328A, Revision 1, which adequately addressed and recorded:
(1) the
. acceptance criteria, (2) the pressure of the test source, and (3) the test results.
The NRC inspector concluded that Revision 1 of EGT-328A, if not substantially changed from the draft reviewed, will adequately provide steps to test and document. test results for the auxiliary feedwater supply line check valves.
Review of the final version of EGT-328A, Revision 1, is an open item (445/8952-o-02).
7.
Significant Meetings (30702)
a.
On July 7, 1989, a meeting between the NRC (Warnick, Livermore, and others) and TU Electric (Cahill, Bruner, Hogg, and others) which was open to the public and attended by CASE (Garde and ottney) was held to discuss TU Electric audit-TSU 89-01 and the audit identified problems associated with the procurement of replacement parts for charging flow control valve 1-FCV-121.
Follow-up meetings were held on July 10 (Warnick and
,
Streeter) and July 20 (Warnick and Livermore with Hogg, l
Guldemand, Redican, McAffee, and others).
The NRC stressed the following points:
l (1)
The audit was an excellent self-evaluation and it identified a significant procurement problem.
(2)
The existing procurement procedures caused the
]
TU Electric staff to follow a convoluted path in order to procure and install the replacement parts.
The replacement parts were procured as
.
"undesignated spare parts" when they were actually needed for a specific purpose rather i
than for undesignated spare parts.
j
\\
i
)
i
.
w-_--_---__-_-_
- _ _ _ -
_
l
.
~
.
.
.
..
.
'
.
The replacement parts were installed as a
.
" temporary modification" even though the change was intended to be permanent.
I NOTE:
On July 20, the applicant reported to the onsite NRC-staff that the procurement procedures are being revised to correct the problems identified by the auditors and others and to make the procurement process more straight forward and easier to use.
(3)
The significance of the auditor's findings was less apparent in the final write-up of deficiency
,
TSU-89-01-01 than in the draft.
The applicant presented a detailed comparison between the draft and the final and stated that the technical content of the draft was not changed.
b.
On July 17, 1989, the NRC (Crutchfield, Grimes, Zwolinski, Warnick, and others) met with TU Electric (Cahill, Scott, Kelley, and others) to discuss applicant proposed changes to the power ascension program.
prior to the start of that discussion, the NRC presented perceived weaknesses in plant operations that the onsite NRC-staff had identified during the augmented inspection team review of the check valve back leakage events (see IR 50-445/89-30; 50-446/89-30) and during other recent operations inspections (irs 50-445/89-37, 50-446/89-37; 50-445/89-24, 50-446/89-24; and 50-445/89-17, 50-446/89-17).
The handout given to attendees is attached to this report.
The NRC indicated (1) the applicant's performance needed to be strengthened to correct these weaknesses and (2) after correcting these weaknesses, the applicant needs to demonstrate to the NRC that these weaknesses no longer exist.
8.
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.
Two open items disclosed during the L
inspection are discussed in paragraph 6.
)
9.
Exit Meeting (30703B)
An exit meeting was conducted August 1, 1989, with the applicant's representatives identified in paragraph 1 of this report.
No written material was provided to the applicant by the inspectcrs during this reporting period.
The applicant did not identify as proprietary any of the materials provided
.
l
r_.
_
.
'
..-.
.
-
.
.
.$
'15-
,
to or reviewed by the inspectors during this inspection.
During this meeting, the NRC inspectors summarized the scope and findings.of the inspection.
i I
,.
!
!
!
l
'
,
)
i
{-
,
1-
_ - _ _ - _ - _ _ _ - _ _ - _ - _ - _
_ _ _
.
ATTACHMENT
-
L
,
1.
Operators and startup failure to follow procedures.
Valving errors to start the 2 backflow events, PT-0102, PT-3701, and PT6401 2.
Operators' lack of sensitivity to the position of valves, j.
Changing the AFW valves out of the proper order of sequence.
l 3.
Operators' failure to recognize the significance of the l
checkvalve backleakage during the precursor event.
4.
Operators' failure to make sure supervision was ^ aware of the 3 check valves that had significant backleakage (precursor event).
,
5.
Supervisors' failure to stay informed of plant evolutions and problems (the system flushing to solve the chemistry problem and the RHR valving problem during the remote shutdown test.
If checkvalve had failed, it would have put RCS water to the RWST.)
6.
Failure to accurately and adequately document the extent of a problem.
(The precursor event Work Request said " repair check valve leakage.")
No TDR on RHR event. No TDR on PT 4401 and QA person doing surveillance did not issue a surveillance deficiency.
7.
Weakness in the documentation of equipment problems in the shift log.
8.
Failure to recognize inoperable equipment.
9.
Failure to recognize and document equipment out-of-service.
10. Lack of adequate communications between the operating shifts.
11. Weakness in the exchange of information at shift turnover.
(Precursor event and April 23 event)
12. Supervision / Management review of problems documented on work requests. (Precursor event)
13. Failure of persons with knowledge of the precursor check valve problems to raise the information to management.
14. The slowness and lack of direction initially demonstrated by TUE following the April 23 event.
15. The perception that " Projects and the Schedule" were driving decisions at the time of the precursor event and the start of HFT.
16. The perception that the Operations staff are not in control of the plant.
- _ _ _ _
_._.