IR 05000445/1989083
| ML20011D667 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1989 |
| From: | Bitter S, Johnson W, Vickrey R, Joel Wiebe Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20011D663 | List: |
| References | |
| TASK-1.C.6, TASK-2.K.1, TASK-TM 50-445-89-83, 50-446-89-83, NUDOCS 8912280210 | |
| Download: ML20011D667 (21) | |
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NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR = REACTOR REGULATION NRC Inspection Report:
50-445/89-83-Permits: CPPR-126 50-446/89-83 CPPR-127
- Dockets: 50-445 Construction Permit-50-446 Expiration Date:
Unit 1: August 1, 1991 (
Unit 2: August 1, 1992 g
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 Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
November 8 through December 5,-1989
/2/8/p</
Inspectors:
S.
D. Bitter, Resident-Inspector, Da'te-Operations Wl
/.1)/9/89 m
W.
D. g hnson, Senior Resident Inspector, Date OpeMtions (Al
$
~2/19l69
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m B.CVickrey,phactorInspector, tate R.
Region-IV
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8912280210 891219 PDR ADOCK 05000445-G PNU
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Reviewed by:
of Ad
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f T.
S.
Wiebe, Senior Project Inspector--
Dat6 Inspection Summary Inspection Conducted: November 8 through December 5, 1989 (Report 50-445/89-83; 50-446/89-83)
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Areas Inspected:
Unannounced resident safety inspection of.
applicant action on previous inspection. findings; follow-up on event
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reports (10 CFR Part 50.55[e]); in-office review of event reports:
(10 CFR Part 50.55[e]); TMI action items (Safety Issue Management:
System Item I.C.6, open; II.K.l.3, closed); initial fuel loading procedure review; preoperational testing inspection program. status; follow-up of the operations and maintenance procedures team-inspection; solid state protection system; reactor trip breaker modifications; cold overpressure mitigation system (COMS) review; and plant tours.and general. inspection activities.
Results:
Within the areas inspected, the applicant's programs and.
implementation of those programs were adequate...The applicant has_
made significant-progress-in addressing.the deficiencies identified-during the plant procedare inspection conducted in July of 1989.
The unresolved item dealing with those deficiencies has been closed;~
the violation concerning records. storage remains.open pending.the applicant's completion of the training.for-records coordinators.
The applicant is making satisfactory progress.in preparing programs:
and procedures for the Startup Testing Program.
During the.
inspection, two open items were identified.
Both concern the'NRC review of the applicant's cold overpressure mitigation system-(COMS).
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l-3-l DETAILS 1.
Persons Contacted
- J. L. Barker, Manager, ISEG, TU Electric
- D. P.
Barry, Senior, Manager, Engineering, SWEC
- J.
W.
Beck, Vice President; Nuclear Engineering, TU Electric
+*O.
Bhatty, Issue Interface Coordinator, TU Electric-
- M. R. Blevins, Manager of Nuclear Operations Support, TU Electric
+D.
M. Bozeman, Chemistry and Environmental Manager, TU Electric.
+J. Brau, Operations Engineering Supervisor, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- W. J. Cahill, Executive Vice President, Nuclear, TU Electric
- H.
M.
Carmichael, Senior QA Program Manager, CECO
+D. N. Corbitt, Manager, Administrative Services, TU Electric.
- W.
G. Counsil, Vice Chairman, Nuclear, TU Electric
- C.
G. Creamer, Manager, Unit 1 Completions Engineering,
TU Electric j
- B.
S. Dacko, Licensing Engineer, TU Electric
+D.
L.
Davis, Manager, Technical Support
+G. G. Davis, Nuclear Operations Inspection Report Item Coordinater, TU Electric
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- D.
E. Deviney, Deputy Director, Quality Assurance (QA),
TU Electric
+*F.
Dunham, QA Issue Interface, TU Electric
+R.
Flores, Manager, Operations Support, TU Electric
- C. A. Fonseca, Deputy Director, CECO
- S.
P.
Frantz, Newman and Holtzinger:
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- J.
L. French,~ Independent Advisory Group
- W.
G. Guldemond, MAaager of Site Licensing, TU Electric
- T.
L. Heatherly, Licensing Compliance Engineer, I
TU Electric d
+*J.
C. Hicks, Licensing Compliance Manager, TU Electric
+*C.
B.-Hogg, Chief Engineer, TU Electric j
+T.
A. Hope, Licensing, TU Electric.
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+D.
L. Hubbard, Manager, Technical Staff Training,_TU Electric
- A.
Husain, Director, Reactor Engineering, TU Electric.
- J.
J. Kelley, Plant Manager, TU Electric:
+C.
F. Kesinger, Accreditation Advisor, TU Electric
- J.
E. Krechting, Director of. Technical Interface, TU Electric.
- J.
L. LaMarca, Manager of Electrical and T & C Engineering, i
TU Electric
+G.
J. Laughlin, Manager,. Instrumentation and Controls, i
TU Electric
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- O.
W.
Lowe, Director of Engineering, TU Electric.
.S.
Lueders, Radioactive Waste Supervisor, TU Electric.
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- F. W. Madden, Mechanical Engineering Manager, TU Electric
- S.
G. McBee, NRC Interface, TU Electric.
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- J.
W. Muffett, Manager of Project Engineering, TU Electric.
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F. Ottney, Program Manager, CASE
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- S.
S. Palmer, Project Manager, TU Electric
- C.
A. Parker, TU Electric
- P.
Raysircar, Deputy Director / Senior Engineer Manager, CECO
- D.
M. Reynerson, Director of Construction, TU Electric
- H.
C. Schmidt, Director of Nuclear Services, General Division, TU Electric
+E.
J. Schmitt, Manager, Radiation Protection, TU Electric
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
+*J.
C. Smith, Plant Operations Staff, TU Electric s
- R.
L. Spence, TU/QA Senior Advisor, TU Electric
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- P.
B. Stevens, Manager of Operations Support Engineering, TU Electric
- J.
F. Streeter, Director, QA, TU Electric
+S.
W.
Swam, Supervisor, Technical Training, TU Electric
- C.
L. Terry, Manager of Projects, TU Electric.
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L. Thero, QTC Consultant to CASE i
+W.
G. Westhoff, Supervisor of Technical Audits, TU Electric l
+B. W. Wieland, Manager, Maintenance, TU Electric j
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G. Withrow, EA Manager, TU Electric.
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- D.
R. Woodlan, Docket Licensing Manager, TU Electric.
- J.
E. Woods, Assistant Project' Engineer, SWEC/ CECO The NRC inspector also interviewed other applicant employees.
during this inspection period.
- Denotes personnel present at the December 5, 1989, exit.
interview.
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+ Denotes personnel present at the hovember 17, 1989,-exit.
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2.-
Applicant Action on_ Previous Inspection Findinas-(92701)
a.
(Closed) Open Item (445/8967-0-02):
Unlanded leads.
identified during preoperational testing. :This item-originated during the-performance of the " Integrated.
Safeguards Actuation Test," 1CP-PT-57-ll. -During that; test, the applicant noted thatLone valve, 1-HV-2399A, did not open when required to do so.-
A test deficiency report-
(TDR) was written to reflect this.
Subsequent trouble--
i shooting revealed that two conductor leads were not landed.
as required.
This discrepancy was tracked as an NRC-open.
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item pending applicant action.as to-the circumstances surrounding the unlanded leads.
I Although the applicant investigated this discrepancy using:
document reviews and discussions with. personnel, the cause
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could not be established.
The applicant-has thus.
concluded that the discrepancy represents an= isolated.
case.
However, the applicant has issued memorandums.that_
emphasize the need.for all personnel to maintain constant
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i-5-vigilance to ensure that finalized (completed) equipment-
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does not undergo unauthorized modifications.
i The inspector--has reviewed the manner in which the applicant addressed this concern and has no further.
questions.
This item is closed.--
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b.
(Open) Open Item (445/8961-0-01):. operational. input to setpoint calculation process.
This item resulted from the.
. inspector's concern that the orarators would not be able to take manual control of the auxiliary feedwater (AFW)
pump discharge valves following an automatic start. signal because the reset setpoints.were adjusted such that reset:
could not occur.
As a result, the operators would not be able to control steam generator level or cool-down rate.
The inspector reviewed letter NE-27,864 which documented the applicant's action with regard to the: inspector's'
concern.
The letter-points out that:
(1) all balance-of-plant (BOP) safety-related setpoint. calculations have'
an. acceptability checklist confirmed by the inputting
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discipline, (2) the adjusted setpointLwas justified by a
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footnote which states that during. faulted conditions the-discharge valves would transfer to automatic at a conservativelv higher discharge pressure and during' normal plant condii4n'? the valves could be placed in manual control, ano
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a review of approximately 25% of the safety-relate setpoint calculations was conducted.
It was determined.that for those calculations reviewed,. the adjusted setpoint and. reset values were within-theirc respective normal operating ranges.
Therefore, the letter concluded that.the existing.setpoint calculation:
review process ensures that sufficient operational ~
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considerations are considered via the acceptability
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checklist.
The inspector determined that letter NE-27,864 does not.
adequately address the NRC's concerns..
(1)
Although it is true that the calculations have acceptability checklists, the checklists for Calculations IC(B)-004, Revision 1, and.IC(B)-008, Revision 1, accept' inadequate setpoints.
The checklist for. Calculation IC(B)-004, Revision 1, accepts a pressure' bistable reset point such that it-may not reset.
The checklist notes-that this..
condition is acceptable because wheh the flow rate.
returns to an acceptable. level, the system can be.
transferred to manual.
However^, as shown by Calculation IC(B)-008, Revision 1, the flow bistable cannot reset because the reset point is below the normal system flow.
The checklist for' Calculation:-
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-6-IC(B)-008, Revisior. 1, accepts a reset point-that is below the normal o9erating flow without any comments.
(2)
The justifications for the setpoints in Calculation IC(B)-004, Revision 1, do not address the inability of the operator to control. steam generator level and cool-down rate.
(3)
It is apparent from the above discussion that the.
applicant did not understand the inspector's concerns.
'As a result, the inspector is not-convinced that the review of 25% of the-safety-related setpoint calculations would have-identified a similar concern.
This open item remains open pending applicant resolution-
of the inspector's concern.
c.
(Closed) Open Item (445/8945-0-01):
Inattention to' detail'
by preoperational test procedure writers.
This item-remained open pending applicant action to reduce the
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number of errors in the. procedures.
The applicant!s QA l
organization also.noted large numbers of errors in the.
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procedures during QA surveillance of the preoperationali
tests.
The applicant held. training sessions for the.
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procedure writers in August 1989.- Since most.of the test-
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procedures had already been written and performed,.the inspector could-not evaluate the effectiveness of the training.
The poor-quality-of the test procedures; appeared to contribute to problems.with procedure:
adherence as documented in past inspection ^ reports.
However, the applicant was successful in obtaining valid.
test results.
Therefore, the inspector. concludes that procedure quality did not adversely affect the-results of:
L the tests.
The startup and low power test procedures appear to.be of.
better quality than the prestart test procedures.
Future inspection reports will document-the. normal NRC inspection.-
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program review of these procedures as well as.the Unit 2-preoperational, startup, and low power test procedures.
Based upon the above, the inspector considers this item; closed.
d.
(Closed) open Item (445/8917-0-01):
HVAC. gravity damper-flow indication and. alarms.
This item arose from the:
closure of construction deficiency SDAR CP-88-02, "HVAC Gravity Dampers."
SDAR Cp-88-02 was closed because the.
applicant determined that the failure of one gravity.
N-damper in the battery' room. ventilation system would notn cause all battery room air flow to cease.
Instead, a.
redundant fan would perform its safety-related function,-
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L-7-maintaining air flow to the battery room.
As a result of the applicant!s evaluation of this issue,. Comanche Peak.
Engineering recommended the addition of instrumentation so that control room personnel would have indication of an adverse heating, ventilating, and air-conditioning (HVAC)-
pressure condition.
The NRC has tracked this
recommendation as an open item.since closure of the.
construction deficiency.
Recently, the applicant responded to this open item..
The applicant has decided to make the modifications in various ventilation systems: so that control room personnel are-aware of adverse HVAC-pressure conditions.-
Because these.
modifications are classified as " enhancements" and are not absolutely required, their completion is of a low priority.
Therefore, there;is no scheduled completion.
date.
The inspector has reviewed the documentation associated with these modifications and is satisfied with the applicant's method of handling this item.
This item is closed.
e.
(Closed) Open Item (445/8884-0-01):
Operability of remote shutdown panel.
This item originated during the resident inspector's review of the NRC's proof-and-review issue of.
Technical Specifications.- The inspector noted that.a list of control circuits and switches for,the. remote shutdown:
panel had.not been placed.in any surveillance procedure..
The applicant responded to this issue by. issuing.
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Operations Testing Procedure. OPT-216A, Revjsion.0, " Remote i
Shutdown Operability Test."
The inspector: has reviewed-this procedure and has determined that it contains the listing of switches and control circuits..Furthermore, it satisfies the surveillance. requirements of Technical.
Specification 4.3.3.2.2.
The inspector has no further.
questions.
This item is. closed.
f.
(Closed)-Unresolved Item'(445/8422-U-06):
Battery room ventilation.
This item originated' when the senior-resident inspector for. operations identified a design; discrepancy -in the Units-1 and. 2 battery rooms.
The:
discrepancy invctved the location and configuration.of.
overhead structural beams in the battery' rooms.
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i specifically, their placement and orientation was such:
that.two large air pockets were formed in-the ceilings ~of the battery rooms.
Because these pockets were not'
directly swept by.the ventilation system, the inspector felt that hydrogen could accumulate.
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-8-After evaluating this concern,.the applicant modified the Unit 1 battery room exhaust ducting and structural supports to ensure. proper ventilation to all areas of the
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battery room.
The inspector-has reviewed the.
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documentation associated with the modification and has no further questions.
Because there 'is no basis for issuing:
a violation, and because the problem has beensresolved (in Unit 1), this item is closed.
It should be noted that-unresolved item 446/8407-U-01 dealing with the same j
discrepancy'for Unit 2 is still open.
It will remain open until the NRC receives documentation concerning its-resolution.
3.
Follow-up on Event Reports (10 CFR Part 50.55[e]) (92700)
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(Open). Construction Deficiency (SDAR CP-86-18):
" Safety.
chilled Water Units."
This item originated when the applicant evaluated numerous difficulties in starting and operating the safety chilled water chiller. units when the entering component, coolant Water (CCW) temperature was not maintained at,oor above, the chilled water return temperature.
The applicant reported this significant. deficiency under the. provisions of.
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As corrective action, the applicant has committed to performing
the following by Unit 1 fuel. load:
a.
Installing an air-operated water regulating valve in the CCW outlet from the chiller condenser.along with a-pressure controller to maintain condenser refrigerant; pressure above evaporator pressure.
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Preventing CCW from circulating through the chiller l
condenser-prior to condenser startup.
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Installing a 30 minute air accumulator tank.for the l
air-operated water regulating valve and installing a hand wheel to manually operate this valve after 30 minutes.-
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Installing similar modifications for the nonsafety chillers (excluding the 30 minute. air accumulator).
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Installing a bypass line to bypass the instrument air compressor jacket after-cooler.
j-1 This SDAR remains open-pending:-
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NRC verification.that the applicant has adequately determined the failure modes of the pressure-controller-and water regulating valve and evaluated the effect on chiller. operation.
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NRC verification that plant procedures adequately address:
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The need to manually control the water regulating-valve within 30 minutes-of losing instrument air pressure.
(2)
The proper instruments and control band for manually-controlling the water regulating valve.
(3)
The need to manually control the water regulating valve as the safe shutdown impoundment and CCW system-heat up following a design basis accident with loss.
of instrument air.
(4)
Required actions if.the pressure control and water regulating feature becomes inoperable.
(5)
The proper use of the bypass line for the instrument-air compressor, c.
NRC verification that plant surveillance procedures or-
logs adequately address:
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The minimum CCW temperature allowed.to consider-supplied components-operable.
(2)
Surveillance of the correct position of the water regulating valve during normal operation.
4.
In-Office Review of Event-Reports-(10 CFR Part 50.55[e])
(90712)
The inspector reviewed significant' deficiency analysis. reports (SDARs) to determine if additional 1 reactive inspection effort:
or other NRC response is warranted, if corrective' action discussed in the applicant's report appears: appropriate, if the
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i information satisfies reporting requirements, if generic issues are present, if the event is appropriate for classification as-an abnormal occurrence pursuant to Section 208 of the Energy Reorganization Act of 1974, and if the event is appropriate for:
the licensing. board, the appeal panel, or commission notification.
SDAR CP-89-031, " Failure of Tornado Dampers to L Open Fully,E'
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(Units 1 and 2) was determined to not warrant additional NRC.
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No violations or deviations were identified.
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TMI Action Items (SIMU)* (25565)
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- The Safety Issue Management System (SIMS) tracking number _is:
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the same as the TMI Action Item number.
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(Open) TMI Action Item I.C.6:
" Verify Correct Performance of Operating Activities."
This item requires the.
applicant to have procedures that include an effective system for verifying the correct performance of operating activities.
NUREG-0737, " Clarification of TMI Action Plan Requirements," contains the guidelines as to how to meet the requirements of this item.
Furthermore, the NRC staff has addressed the applicant's progress in meeting these.
requirements in NUREG-0797, "CPSES SER," and Supplement I i
to the SER.
During this inspection period, the-inspector reviewed the.
applicant's progress toward meeting the requirements of this action item.
The inspector has determined that the applicant needs to address two concerns before this action item can be closed.
These concerns are:
The applicant originally committed to using-licensed.
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operators as " qualified operators" for the purpose of-
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performing independent verifications:(second checks)
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for tagging, return-to-service, etc.
This commitment.
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was discussed in Supplement I to the CPSES.SER..
Recently, the applicant submitted an FSAR. change that allows auxiliary operators to perform the independent verifications.
Furthermore, the inspector noted that Procedure STA-601, " Authority for Equipment:
Operation," Revision.5, allows instrument and control (I and C) technicians to' perform independent:
verifications (second checks) of instrument. valves.
The applicant should clarify the apparently-conflicting policies.
The inspector reviewed several. procedures in an i
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attempt to understand the controls for ensuring that all su::veillance procedures will contain steps:that.
I direct a " qualified operator" to perform independent verifications (second checks) of components prior to returning the component.(system) to. service.
The following procedures were reviewed:
STA-601, Revision 5, " Authority for Equipment Operation" STA-702, Revision 7, " Surveillance Test Program" ODA-206, Revision 4, " Preparation of Operations Test Procedures and Equipment Test Procedures" After reviewing these procedures, the inspector was unable
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to determine how the requirement to perform independent ~
verifications.for surveillance testing will be ensured.
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-11-This item remains open-pending the applicant's resolution-of the above issues involving these two concerns.
b.
(Closed) TMI Action Item II.K.l.3:
"NRC Bulletins."
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item had remained open pending the NRC's verification that-the applicant has adequate controls in place to ensure
proper engineered safety feature (ESF) functioning and to i
ensure that operability status of safety-related systems.
is always known.
I The inspector verified that the applicant has sufficient controls in place to ensure proper ESF functioning.
The i
inspector, reviewed Instruction OWI-103, Revision 3,.
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" Operations Department Locked Valve Control."
This, procedure provides Operations Department personnel'with a method for controlling,. maintaining, and verifying-locked-in-position valves and breakers by means of chain.
or cable and padlocks or seals.
In general, the applicant.
uses this instruction as-well as the valve lineups called for in the Standard Operating Procedures to ensure that.
valve, breaker, and switch lineups are. controlled to ensure proper ESF functioning.
The inspector reviewed Operations Procedure ODA-308,
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Revision 0, "LCO Tracking Log," to verify that the-
applicant has a method to remain aware of the operability status of safety-related systems.
This. procedure-provides-Operations Department personnel with a method of.
documenting and tracking degraded Technical Specification-limiting conditions for operations (LCOs), required actions, reporting, and testing requirements.
After reviewing the manner in which the applicant addressed and met the requirements of this action item, the inspector has no further questions.
This item is closed.
6.
Initial Fuel Loading Procedure Review (72500)
The NRC inspector continued the review of procedures to:be used during initial fuel loading.
Since eleven of these procedures.
were being revised at the end of this inspection period, this_
review could not-be completed.
No violations or deviations were identified.
This review will be continued in the next inspection period.
7.
Preoperational Testing Inspection Program Status (40301, 64703, 70324, 70352, 70400, 70436, 70452, 70552)
Inspection Modules 70352, 70452, and 70552 of NRC Inspection.
Manual Chapter 2513 concern the remote reactor shutdown test-
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procedure review, test witnessing, and results review, respectively.
Originally, these modules were not considered.
complete because the reactor shutdown portion of the test" cannot be performed until af ter fuel load.
However, Inspection Modules 72300,~72583, and 72301 of NRC Inspection Manual.
Chapter 2514 identify the same inspection requirements'for the.
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remote shutdown test.
Therefore, Inspection Modules 70352,-
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70452, and 70552 are administratively considered complete.. The.
remaining inspection effort for the remote reactor shutdown-test will be accomplished by Inspection Modules 72300, 72583, and 72301 as appropriate.
Inspection Module 70324, " Integrated, Hot Functional Test, Results Review" of NRC Inspection Manual Chapter (MC) 2513 includes the inspection requirements for performing the results l
review of integrated system operation at minimum self-sustaining power level.
This condition cannot be achieved until after fuel load.
MC 2514 provides the inspection.
requirements for power operation (Inspection Modules 72600, 72608, 72616, and 72624) including the results reviews.
Therefore, Inspection Module 70324 is administratively
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t considered complete.. Inspection of testing at power will be performed using the appropriate MC 2514 inspection module.
Inspection Module 70400, "Preoperational. Test Result-Evaluation" of NRC Inspection Manual Chapter 2513 is a-generic.
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procedure that is-referenced by other. inspection modules.
This inspection module had been left open because two referencing-modules (70324 and 70552) were not yet complete.-
As discussed, above, these referencing modules are now considered complete.
Therefore, Inspection Module 70400 is also considered complete.
Inspection Module 64703, " Fire Prevention / Protection" is required by NRC Manual Chapter 2513.
This module was replaced.
by Inspection Module 64704. _ Inspection Module 64704 was completed by Inspection Report 50-445/89-69; 50-446/89-69.
The inspection requirements of Inspection Module 64703 are therefore considered complete.
Inspection Module.40301, " Safety Committee Activity Inspection" l
is required by NRC Inspection Manual Chapter 2513.
This module
was replaced by Inspection Module 40500, " Licensee Self.
Assessment Capability."
Inspection-Report 50-445/89-72; 50-446/89-72 documented an-inspection in accordance with the.
applicable portions of Inspection. Module.40500.
Inspection _
Module.40301 is therefore considered complete.
Inspection in.
accordance with the remainder of Inspection Module 40500 will occur following plant licensing as. required by the NRC.
Inspection Manual Chapter-2515.
Inspection Module 70436, " Residual-Decay Heat Removal System'
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Test Witnessing" is an optional inspection for the NRC MLnual
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-Chapter 2513 inspection program.
The test to be witnessed was accomplished during the " Hot Functional Test" and the
" Integrated Test Sequence." -As a result, the inspection time-was charged--to Inspection Modules 70314, " Integrated Hot
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Functional Test Witnessing," and 70315 " Engineered Safety'
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Feature Test."
Inspection Module 70436 is, therefore, considered complete.
8.
Follow-up of the Operations and Maintenance Procedures Team Inspection (50-445/89-57; 50-446/89-57) (42400, 42450, 42451, 92701, 92702)
a.
Background During the-period July 19 through July 28,_1989, a Procedure Review Team (PRT) conducted an inspectioniof.
operations and maintenance procedures for Unit-1.
The.PRT based its inspection on the criteria outlined in NRC Manual Chapters 42400 (Plant Procedures Inspection),
42450 (Operating Procedures Inspection), and 42451 (Maintenance Procedures Inspection).
These areas were inspected for the following objectives:
To confirm.that the scope of the plant procedures-
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system is adequate to control safety-related operations within applicable regulatory requirements, To determine the adequacy of management _ controls in.
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implementing and maintaining a viable. procedure.
system, To confirm that the plant maintenance procedures are
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prepared to' adequately control maintenance.of safety-related systems within applicable regulatory requirements, and.
To ascertain whether plant emergency procedures are
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prepared to adequately control safety-related functions in the event of system or component.
malfunction indication.
During the review,-the team. identified approximately 200 concerns dealing with five different areas of the procedure review.
These areas were:
format, procedure:
changes, consistency, procedure references, and-technical adequacy.
Although the majority of.these items.were individually minor in nature, the. team. felt that the applicant should not only address the individual concerns,.
but should also take a. closer look at their generic implication.
Collectively, the items were tracked as an, unresolved item (445/8957-U-02),
Procedural Problems.
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y Found During PRT Inspections."
Also identified.during the, m
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-14-inspection was a violation (445/8957-V-01) concerning the-
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failure.to properly implement all.the applicable.
administrative controls for in-process documents-b.
Inspection Activities / Methodology To supplement the previous inspection activities,.the inspectors reviewed an additional sample of the applicant's procedures and reviewed the applics.nt's
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response to the above mentioned unresolved item and.
violation.
The following procedures were reviewed:
ABN 107A, Revision 1,
" Emergency Boration."
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ABN 603A, Revision 0, PCN 1, " Loss of Protection or
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Instrument Bus."
ABN 712A, Revision 3,
" Rod Control System.
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Malfunction."
SOP 108A, Revision 2, PCN 1, " Reactor Coolant Pump."
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SOP 202A, Revision 4, " Safety Injection
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SOP 702A, Revision 2, " Rod Control System."
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MSM-CO-3830, Revision 0,E" Emergency Diesel Engine
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Disassembly and Assembly."
i MSM-SO-8702, Revision 0, PCN 1, " Main Steam. Safety-
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l Valve Setpoint Verification."
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MSE-PO-6000, Revision 0, PCN 1, "6.9kV Switchgear-
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Cleaning and Inspection."
MSE-SO-6301, Revision 0, PCN 5,
"6.9kv Air-Circuit.
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Breaker Inspection and Cleaning."
MSE-SO-6301, Revision 1, Draft Copy.
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The inspector also reviewed the' Master Procedure Index.and.
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controlled copies of procedures during.this inspection.
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Results/ Findings.
l During the inspectors' review of the ABNs and SOPS.
mentioned above, no errors were found that were associated.
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plant.
The procedures were not. difficult to follow; they
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were. complete, and setpoints agreed with settings as specified in the Technical Specifications.
Two minor-
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typos and one inconsistency were noted.
The inconsistency-l involved the way that the procedures rufarred to Technical, Specifications.
Sometimes the Technical Specification number.and title were used; other times, only the number was used.
The procedures appeared to have been significantly improved during their revision since the inspection in July.
These procedures appeared to be-
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technically correct and usable by operation personnel..
Improvements appear to have been made in the review cycle
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of these procedures.
Review of the maintenance procedures listed above resulted i
in similar findings.
There were no technical inadequacies and significant. improvements'had been made with respect to-consistency, format, and. useability.
During the revision.
process, the procedure writers.not only incorporated:the PCNs, but took additional steps to enhance the quality of.
the procedures.
The inspector did note, and did bring to.
the attention of the procedure. writers, some typo errors, created from PCNs and revisions, and somenminor suggestions for quality improvement.
(Closed) Unresolved Item (445/8957-U-02):
Procedural problems found during PRT. inspection.
The inspector.
reviewed the records of'the applicant's disposition:of: the.
nearly 200 concerns listed.-
For the generic concerns, the inspector reviewed the details andLdocumentation conducted; by the operations and electrical maintenance.
organizations.
During these. reviews, the inspector-conducted random sampling of the: committed actions to
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verify their completeness.
The ' applicant, has recognized-
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the concerns of the NRC, assessed.the generic-implications of the concerns,.and has taken. quality corrective action in a timely manner.
This item is closed.
(Open) Violation (445/8957-V-01):
Failure to properly implement all of the applicable administrative controls for in-process documents.
The. inspector reviewed the.
corrective actions that were complete and-that were
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in-process.
This review included visits to three records.
storage areas and discussions with~the. respective-records'
coordinators.
Of the. areas reviewed, the inspector saw:
significant. improvements being: made -in response to the-violation.
The I&C backlog had been reduced to a manageable level and that level was being tracked to keep-
'it down.
Records coordinators had been assigned and given.
responsibilities.
For the most part, facilities for
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establishing proper storage and control had been
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Some programs were not yet' fully i
implemented;.these included:
Posting of areas and access. control,
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i Obtaining necessary storage containers,
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Establishing a filing and recording system that J
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identifies documents stored.in the areas, and.
Establishing a method to audit the record files to
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periodically verify accountability.
The records coordinators had been informed of their-duties.
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and responsibilities but had not yet received training on.
how they should implement them.
Interviews with the three records coordinators revealed a lack of standardization in the methods used to maintain records.
This violation remains open awaiting the licensee's full.
implementation and establishment of a method to audit the
.j record files to verify accountability.
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Conclusions During this review, the inspectorafound.that procedures are being limited to five PCNs prior to revision.- Furthermore, the.
revisions that were reviewed have enhanced the-procedures with.
a minimal number.of typo / paragraph numbering errors.
No concerns were identified dealing with format,_ procedure.
changes, consistency, procedure references, and. technical adequacy of the procedures reviewed.- The licensee'has.
established what appears to.be a satisfactory administrative program for generation, implementation, and control.of plant operating procedures.
Therefore,.the inspector has determined.
that the procedures appear to be adequate to support safe operation and. maintenance.of the plant.
9.
' Solid State Protection System (25014)
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The ' inspector reviewed controlled ~ drawings and. confirmed that the-drawings show that the manual trip; circuits are located:
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downstream:of. output transistors ~Q3'and Q4.
This arrangement ensures that the manual trip circuits: willi cause a reactor trip if output transistor Q3 is shorted.
To ensure that the actual.
H configuration was in accordance with the. drawings, the-
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inspector-traced the installed wiring.from the.undervoltage.
card (transistors Q3 and Q4) to the manual trip switch.
No.
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deviations from the_ drawings were identified..
This inspection _
completes the' inspection requirements of Temporary Instruction:
(TI) 2500/14, " Inspection of the Location of the Manual Trip.
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-17-Circuit in Westinghouse - Designed Plants with a Solid State.
Protection System (SSPS)."
10.
Reactor Trip Breaker Modifications (SIMS Item MPA B-80) (25591)
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Generic Letter 83-28, " Required Actions Based on. Generic Implications of Salem ATWS Events," dated July 8, 1983, required in item 4.1 that all vendor-recommended reactor trip breaker modifications be reviewed to verify that either:
(1) each modification has been implemented, or (2) a written-
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evaluation of-the technical reasons for not implementing a-modification exists.
By letter TXX-4071 from B. R. Clements-(TUGCO) to D. G.
Eisenhut (NRC) dated November 3, 1983, the_
i applicant committed to replace the existing undervoltage trip.
l attachments (UVTA) on all reactor trip breakers as soon as they'
became available.
This action was recommended by Westinghouse:
letter NS-EPR-2753 dated April 21, 1983, and was the only modification identified for the DS-416 trip breakers installed
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at CPSES.
In the Technical. Evaluation Report attached to a letter from.
V.
S. Noonan (NRC) to M. D. Spence (TUGCO) dated December.5, 1985, the NRC stated that the applicant's response to item'4.1 of Generic Letter 83-28 was acceptable.
The acceptability of-the applicant's response is also documented in-Section 7.2.6(4)
of Supplement 21 to the CPSES Safety Evaluation Report. dated-
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April 1989, i
The inspector verified that the recommended modification.was implemented.on the reactor trip breakers.. A review of the:
implementing documents showed.that a Westinghouse-representative was involved with the modification and that the modification had been satisfactorily tested.
The inspector:had.
no further questions regarding this-issue.
The inspection requirements.of Temporary Instruction 2515/91,
" Inspection Follow-up to Generic Letter 83-28, Item 4.1" are.
considered complete.
This inspection al'so completes the
inspection verification for SIMS item MPA B-80.
No problems were identified.in this area.
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11.
Cold Overpressure Mitigation System (COMS) Review (SIMS Item l;
A26) (25019)
O The inspector reviewed the setpoint determination documentation-for the CPSES COMS.- The inspector determined that the COMS setpoints.do not take.into account pressure. instrument error.-
t As a result, under certain conditions the system will not-maintain primary pressure below the 10 CFR 50, Appendix'G limits.
The applicant's position is based on_ conservative.
assumptions in the, development of the pressure - temperature-I
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-18-limits and in the power operated ~ relief valve (PORV) setpoint-analysis.
This issue is considered open pending additional NRC-review of the basis and acceptability of this position (445/8983-0-01).
The inspector verified that the design of the system considers a single failure in addition to a failure that initiated the pressure transient.
In addition, the design of the system is
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such that it is not vulnerable to either an event that causes a pressure transient, or to a failure of equipment needed.to terminate the transient.
The inspector verified that the setpoints are supported by a plant specific analysis.
The inspector notes that the analysis assumes that the PORV opening and closing times are two.
seconds.
A review of the PORV test data showed that the PORV opening time was in specification; however, the PORV closing time was greater than two seconds..This issue is considered open pending applicant's determining whether the PORV closing.
g time adversely affects the setpoint analysis (445/8983-0-02).
i The inspector reviewed the operating procedures to determine if the time in a. water-solid. condition was minimized.
Integrated Plant Operating Procedure.IPO-005A, " Plant Cool-down from Hot standby to Cold Shutdown," Revision 5, dated-October 10, 1989, indicated that the pressurizer should.be taken to the water-solid condition if " desired."
No further guidance was given.
The' inspector discussed with the applicant _the-desirability of including'a statement'in the procedure to minimize the time in a water-solid condition.
The applicant agreed to include such a statement.
The temperature differentials between steam. generators and reactor vessel while in a water-solid condition should be-i minimized to reduce the pressure transient caused'by the mixing-
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of different temperature water.
The applicant's procedures.
minimize this pressure transient in several ways.
The.
procedures do~not allow starting reactor coolant pumps (RCPs)
y in a water-solid condition unless.the reactor 1 coolant system is p
in the process of being filled and vented.
The procedures and.
I technical specifications do not allow starting a RCP in modes:4 or5ungesssteamgeneratorsecondarywater.temperatureisless-than 50 F greater than each of the reactor coolant system cold.
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leg. temperatures.
In addition,.if'all RCPs have been stopped-
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for more than 5~ minutes during heatup and'the reactor coolant'
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temperature is greater than the charging and' seal. injection
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water temperature, RCP restart will not be attempted until a-steam bubble is formed'in the pressurizer.
Furthermore, if all
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RCPs are stopped and:the RCS is being cooled down by the.
residual heat removal. heat exchangers, RCP restart will not.be attempted until a steam bubble is formed in.the pressurizer.
The procedures also require.at least one reactor. coolant pump
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-19-to be in servige until the reactor coolant temperature is reduced to 160 F.
To prevent a pressure transient caused by
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inadvertent pressurizer heater operation, the heater breakers
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are tagged in the open position.
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The procedures and technical specifications require all safety
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injection pumps and one charging pump to be inoperable when the g
reactor coolant is less than 350 F.
This limit ensures that
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any pressure transient can be terminated by the operation of one PORV.
A high pressure alarm is activated in the control room at a'
pressure below the PORV setpoints.
The operator is therefore alerted to the pressure transient and has the opportunity'to i
correct the cause.
The inspector verified that the applicant's
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training program includes training concerning low-temperature.
overpressure events.
l The applicant's surveillance program and Technical Specifications require the performance of an Analog Channel Operational Test on the PORV actuation channel within 31 days
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prior to entering a condition in which the PORV is required to
be operable and at least once every 31 days when the PORV is required to be operable.
In addition, a channel calibration on.
the PORV actuation channel is required at least.every-i 18 months.
Based on the abovo, the inspector determined that the installed
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Cold Overpressure Mitigation System is in accordance with the
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Plant commitments.
The above inspection completes the
inspection requirements of TI 2500/19, " Reactor "essel Pressure Transient Protection."
The verification.of SIMS Item A26 will remain open pending resolution of the two cpen items.
l 12.
Plant Tours and General Inspection Activities (71302)
The inspectors conducted numerous plant tours during this,
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inspection period.
These tours provided coverage during normal, off-normal, and backshift working hours..NRC
inspection activities included, reviewing work documentation, witnessing ongoing work activities, discussing plant status.
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with plant management, observing and. interviewing shift i
operations personnel, determining the readiness of Unit 1 for fuel load and operations, observing housekeeping activities,
and inspecting for general safety compliance.
To support these activities, NRC inspectors attended.
i plan-of-the-day meetings, discussed. plant status with
operations personnel, and attended meetings dealing with the.
L future Unit 1 fuel load.
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O-20-The NRC inspector examined the exterior of Recirculation Sump 1 for general integrity and cleanliness.
Cleanliness was satisfactory with only minor dust present.
Integrity was generally satisfactory but a number of 1/4-inch and 1/2-inch bolts and nuts were missing on the inner and outer screens.
The system engineer informed the NRC inspector that Nonconformance Report (NCR) M85-101773, Revision 2, had
_
identified a similar condition on Recirculation Sump 2.
This NCR had been dispositioned "use-as-is."
The system engineer noted that a similar NCR existed for Recirculation Sump 1.
When this NCR is located, the NRC inspector will review it with the system engineer.
The work package for Work Order C890016002 was reviewed with construction operations support group personnel.
This job involved replacement of a gasket flange in the primary sampling system.
No discrepancies were identified in the work package.
The NRC inspector observed the performance of a surveillance test on the Train A emergency diesel generator.
The test was conducted in accordance with Procedures OPT-214A and SOP-609A.
During this engine run, the post-work tests associated with the following work orders were observed and no procedural discrepancies were noted:
C890016587 C890015071 C890009197 C890015631 C890010554 During a tour of the containment building, the NRC inspector observed that certain instrumentation was disconnected from the.
seal area of the reactor coolant pumps.
The reactor coolant-system work order list was reviewed with the system engineer to verify that work orders were outstanding to reconnect this instrumentation.
These work orders were completed later in the inspection period following recoupling of the reactor coolant pumps.
Torquing of the coupling nuts on the No. 4 reactor coolant pump was observed.
This was performed under Work Order C880001846.
The NRC inspector also observed the cleaning of the upper bearing insulation on the No. 3 reactor coolant pump.
This work was performed under Work Order'C890016728.
No discrepancies were noted.-
The NRC inspector observed a portion of the implementation of Design Modification (DM)89-269 on the reactor protection.
system.
This DM modified the' circuitry to allow block testing-of the feedwater split flow bypass valves to enable quarterly testing of slave relays per Section 7.1.2.5 of the Final Safety Analysis Report.
The work package at the job site was complete and the implementation; instructions were being followed by TV Electric instrumentation and control technicians, i
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-21-The NRC inspector observed a portion of the implementation of DM 85-272.
This DM was performed under Work Order C890007685 to replace the incore seal table fittings.
The NRC inspector-noted that the implementation instructions were being followed i
by TU Electric mechanical maintenance technicians and that.
proper cleanliness. controls were in effect.
i During plant tours, the NRC inspectors noted several.
housekeeping and minor material discrepancies.
These were identified to TU Electric personnel for corrective action..
13.
Open Items-
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Open items are matters which have been discussed with the i
applicant, which will be reviewed further by-the inspector, and which involve some action on the part of the NRC or licensee or
both.
Two open items disclosed during the inspection are
discussed in paragraph 11.
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14.
Exit Meetings (30703)
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Exit meetings were conducted on November 17 and December 5, j
1989, with the applicant's representatives. identified in-
paragraph 1 of this report.
No written material was provided.
i to the applicant by the inspectors during this reporting l
period.
The applicant did not. identify as proprietary any of l
the materials provided to or reviewed by the inspectors during
this inspection.
During-these meetings, the NRC inspectors summarized the scope and findings of the inspection.
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