IR 05000445/1993011

Insp Repts 50-445/93-11 & 50-446/93-11 on 930131-0306. Violations Noted But Not Cited.Major Areas Inspected:Onsite Followup of Events,Operational Safety Verification,Initial Fuel Loading & Startup Test Witnessing

ML20056C122
Person / Time
Site:	Comanche Peak
Issue date:	03/23/1993
From:	Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20056C116	List: IR 05000445/1993011 ML20056C115
References
50-445-93-11, 50-446-93-11, NUDOCS 9303300107
Download: ML20056C122 (5)

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APPENDIX-

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

t Inspection Report: 50-445/93-11 1 50-446/93-11 Operating Licenses: NPF-87 NPF-88 ,

Licensee: TU Electric ,

Skyway Tower '

400 North Olive Street Lock Box 81 Dallas, Texas 75201  ;

Facility Name: Comanche Peak Steam Electric Station, Units I and-2  !

Inspection At: Glen Rose, Texas

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l Inspection Conducted: January 31 through March 6, 1993 l Inspectors: D. N. Graves, Senior Resident Inspector I R. M. Latta, Resident Inspector i G. E. Werner, Resident Inspector j D. L. Kelley, Reactor Inspector ,

S. K. Malur, Operations Engineer, NRR  ;

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Accompanying Personnel: K. M. Kennedy, Project Engineer

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V. G. Gaddy, NRC Intern i Approved: @ cuda 7_S.M93

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L. A. Yandell, Chief, Project Section B Date [

Division of Reactor Projects  ;

Inspection Summary

.l Areas-Inspected (Unit 2): Routine, unannounced inspection of onsite followup j

. of events, operational safety verification, initial fuel loading, startup test ,

witnessing, maintenance and surveillance activities, followup on corrective !

actions for a violation, other followup, and Safety Evaluation Report review !

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Areas Inspected (Unit 1): No inspection of Unit I activities was performe t i

Results (Unit 2): i

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+ The licensee's response to the broken compensator spring housing on !

motor-operated Valve 2-8809B was good; however, a noncited violation was identified regarding deficient maintenance procedures (Section 2.1).

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• The response of site personnel to a spurious site evacuation alarm ;

indicated that uncertainties exist as to licensee management's !

expectations regarding site alarms (Section 3.2).

• In general, initial fuel loading activities were well controlled and ;

good personnel performance was observed. One procedural weakness was :

identified during the performance of Surveillance Procedure OPT-488A (Section 4).  !

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• Startup testing was performed with excellent communications, coordination, and execution (Section 5).  !

• Maintenance and surveillance activities were well performed (Sections 6 -t f

and 7).  ;

4 f Results (Unit 1): Not applicabl Summary of Inspection Findings: i

• A noncited violation was identified (Section 2.1). f

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• Inspection Followup Item 446/9311-01 was opened (Section 3.2). ,

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• Violation 445/9216-01 was closed (Section 8).

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• Inspection followup Items 446/9260-04 and 446/9302-04 were reviewed but i not closed (Sections 9.1 and 9.2). l

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• Attachment - Persons Contacted and Exit Meeting  !

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1 PLANT STATUS (71707)

At the beginning of this inspection period, the plant was essentially !

complete, with final preparations being made for fuel loading. Facility Operating License NPF-88 was issued on February 2, 1993, authorizing reactor I operation and testing up to 5 percent thermal power. Operating Mode 6 i (refueling) was entered on February 4, and fuel loading activities were completed on February 7. Operational Mode 5 (cold shutdown) was entered on :

February 11, and Mode 4 (hot shutdown) was entered on March 6. At the conclusion of this inspection period, the plant was in Mode 4 and preparations were in process to enter Mode 3 (hot standby).  ;

2 ONSITE RESPONSE TO EVENTS (93702, 92701)

2.1 Cracked Compensator Spring Housing on Motor-0perated Valve j On February 22, 1993, while disassembling the actuator for motor-operated 3 Valve 2-8809B, the Train B residual heat removal injection valve to reactor i coolant Loops 3 and 4, the actuator housing cracked while removing the !

fasteners which connected the compensator spring housing to the actuator !

housing. As a result of an unsuccessful leak rate test, Valve 2-88098 was closed in preparation for disassembly and repair in accordance with Work

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Order 1-93-039628-00. During the disassembly of the last three fasteners on i the compensator spring housing, the compressed tension on the belville washers in the compensator housing cracked the housing flange. Subsequent to this (

occurrence, the licensee suspended work activities on Valve 2-8809B in order j to evaluate the inciden ,

Operations Notification and Evaluation (ONE) Form 93-518 was initiated to i-document the housing failure and to identify and resolve any issues resulting ;

from the investigation. The licensee's investigation of the event concluded

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that the applicable Maintenance Procedure MSM-CO-6854, "Limitorque SBD-3 ;

Maintenance " Revision 0, did not contain a properly sequenced prerequisite to place the valve in a midposition prior to actuator disassembly. Consequently, with the valve in the fully closed position, the belville washers in the ;

compensator housing were in compression and, as the fasteners retaining the j spring housing were removed, the spring force was dynamically released and the :

actuator housing cracked. No injuries resulted from this event; however, a i potential for. personnel injury did exis The inspectors reviewed the applicable vendor manuals with respect to !

maintenance and disassembly of the motor-operated valve actuators. Based on this review, it was determined that the vendor manual described the ,

disassembly process, including a warning regarding the potential for personnel injury. if the compensator spring housing is removed under load. The warning ;

was annotated following the step in the vendor manual where the spring housing ;

would have been removed; however, as . documented in the licensee's - ,

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t investigation, .this warning was not correctly identified and incorporated into i

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the mechanical maintenance procedure. Subsequent to the identification of this procedural deficiency, the procedures governing the maintenance on motor- :

operated valve actuators were revised by the licensee to incorporate a caution ,

that the valve should be placed in midposition prior to actuator disassembl ;

A second unexpected event occurred during valve packing removal when the .j packing was forced out of the valve, causing a minor hand injury to one of the ;

maintenance personnel involved with this activity. Operations Notification  !

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and Evaluation form 93-523 was initiated by the licensee to document and investigate this event. The adequacy and installation of Tagout l Clearance 2-93-0809 for this work activity was reverified by the maintenance t workers and by operations and was determined to be satisfactory. No external  ;

pressure source was identified and all valves were determined to be in the proper positions. The licensee's investigation of the unexpected event  :

concluded that a pocket of pressure had been trapped in the upper valve bonnet ;

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when the valve was in the fully closed position. The top portion of the valve gate formed a seal between the valve bonnet and the remainder of the' system *

piping, effectively trapping system pressure in the bonnet at the time of  !

valve closure. Therefort, during the removal of the valve packing, this j trapped pressure forced the remaining packing rings out of the packing glan ' Although no serious personnel injuries occurred, the potential was presen }

The corrective actions addressing the placement of the valve in midposition l prior to valve and actuator disassembly also eliminated the possibility of J trapping pressure in the bonne !

In order to evaluate the adequacy of the licensee's corrective actions for f this event, the inspectors reviewed the controlling work order, the associated !

tagging clearance order, the vendor technical manual, and the revised  !

maintenance procedures. Although the maintenance procedure was deficient in

. not providing a caution or warning regarding the valve position prior to - !.

disassembly of the valve actuator, once the event occurred, the licensee  :

promptly documented its occurrence and performed a comprehensive review and i investigation which resulted in corrective actions which should preclude  :

recurrence. This violation will not be subject to enforcement action because  !

the licensee's efforts in identifying and correcting the violation meet the ,

criteria specified in Section VII.B.2 of Appendix C to 10 CFR Part .!

i 3 OPERATIONAL SAFETY VERIFICATION (71707) l

! Plant Tours ,

During routine plant tours, the inspectors observed that the general state of i housekeeping.had declined from previous inspection periods. While overal !

. plant cleanliness was good, the storage of support material, such as j scaf folding and the completion of installation activities associated with  ;

Thermo-Lag fire barrier material, added to the degraded appearance in several l area ;

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-5-The inspectors verified that roving fire watches were performing their rounds as required. Based on a selected examination of the fire-watch logs and observation of the fire watches performing their duties, the inspectors determined that the fire watches were being appropriately conducte During tours of the control room, the inspectors determined that the operators were attentive to plant status and responded appropriately to annunciated conditions and that the unit logs were being appropriately maintaine Limiting conditions for operation were addressed and tracked appropriately in accordance with operations department administrative procedure One observation made by the inspectors and communicated to the licensee was that the unit status boards in the technical support center addressed Unit 1 but not Unit 2. The licensee's emergency planning organization stated that they were aware of the status boards and were considering whether any changes needed to be made to address both unit I 3.2 Facility Response to Spurious Site Evacuation Alarm On March 4, 1993, at approximately 2:45 p.m., a site evacuation alarm actuated. Not hearing any further announcements over the plant-wide paging system, the inspectors proceeded to the control room to determine the source of the alarm. On the way to the control room, the inspector observed that several people in the halls and on the street outside the turbine building were proceeding with what appeared to be normal, routine activities, and apparently ignored the alar Upon entering the control room, the inspectors queried the shift supervisor as {

to the cause for the evacuation alarm. He stated that the alarm was l apparently a spurious actuation and was being investigated. The alarm does' !

not have an automatic initiation feature and is only actuated manually from the control room. He indicated that the alarm had not been manually actuated and that no condition existed that would have warranted actuation of the al arm. When asked by the inspectors, he also indicated that no plant announcement had been made to alert the site staff that the actuation was spurious. The inspector noted to the shift supervisor that no one observed by the inspectors paid any attention to the evacuation alarm, even though no j

announcement had been made to alert them as to whether the alarm was valid or not. This observation was communicated to the Manager, Operations and the !

Vice President, Nuclear Operations by the inspector j During the licensee's plan-of-the-day meeting the following day, the Vice President, Nuclear Operations requested that the various group managers define ;

their expectations regarding expected personnel actions following evacuation :

alarm actuations, especially if there is no amplifying information provided, '

and to be ready to discuss those expectations the following week during a weekly manager's meetin The inspector attended the weekly manager's meeting and noted that the licensee had initiated action to test the alarm system. At the close of this

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inspection period, the licensee was still reviewing management's expectations regarding expected personnel actions following evacuation alarm actuations, i especially if there is no amplifying information provided. The followup to :

the licensee's resolution of this issue is identified as an inspection ' ,

followup item (446/9311-01). l 3.3 Land Vehicle Bomb Threat Security Plan ,

The inspectors reviewed the licensee's plans for action based on a land based ,

vehicle bomb. The inspectors confirmed that the licensee had procedures to take actions based on a perceived threat, and that the capability existed for l the actions to be implemented in a timely fashio !

3.4 Conclusions  :

Housekeeping and plant equipment conditions were generally good. A potential weakness in the site personnel response to a site evacuation alarm was identified, and licensee management was responding with more emphasis on i defining response expectations and informing the site staff of those !

expectations. The licensee's land based vehicle bomb threat procedure was l verified to be responsive to NRC generic correspondenc .

4 INITIAL FUEL LOADING (72524) l During this reporting period, the inspectors witnessed the Unit 2 initial fuel )

loading activitie These inspection activities, which were conducted ,

continuously over several days, included the observation of various aspects of l the fuel loading activities from the containment building, control room, and i the fuel buildin l Fuel Load Witnessinq j The inspectors observed the performance of Procedure RFO-501, " Refueling Machine Closeout Instructions," Revision 4, and an analog channel operational test on Source Range Channel 2-N31. The source range channel test was j performed in accordance with Procedure INC-7381B, " Analog Channel Operational :

Test. and Channel Calibration Neutron flux Source Range, Channel N31," J Revision 0. Both activities were performed appropriately with the inspector .j noting good procedure use, good self-verification, and excellent- l

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communication The inspectors commenced Unit 2-fuel load coverage at 4 p.m. on-February 3, 1993. During the initial part of the coverage, the inspectors examined the licensee's preparations for fuel loading by touring the main fueling control ~

stations in the reactor containment building, the fuel handling building, and the control room. The inspectors also reviewed the governing fuel loading Procedure RF0-102, Revision 6, " Refueling Operation," for adequac Additionally, instrumentation calibrations needed for the fuel loading were verified curren ?

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During the final reactor vessel inspection prior to commencement of fuel loading, a small piece of debris was discovered on top of the core plate. The  ;

debris which appeared to be a small piece of cotton _ thread was removed and ,

preparations were continued. An additional delay was encountered when the i 8-hour time limit for the temporary and permanent source range detectors' ,

response calibration expire j

> The licensee placed the first fuel assembly in the reactor vessel at 2:30 h on February 4, 1993. Over the period of the initial core load, the inspectors ,

observed the licensee's fueling operations at the various control- points  !

, during the licensee's fueling shifts. The inspectors observed fuel movement i operations in the fuel handling building and accompanied licensee personnel on the fueling machine during placement of fuel in the reactor vessel. 'The 'l~

inspectors periodically monitored the inverse count rate ratio, verified the accuracy of the core status board, and observed licensee fueling personnel in '

the control room. ~ The fueling crews were knowledgeable of the procedures and i were deliberate in their actions. Appropriate control of the fueling  ;

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operations was exercised at all times by the-senior operator in charge. No i deficiencies were identified by the inspectors in the maintenance of the core  !

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status board. One observation noted by the inspectors was that the operators in the fuel building did not directly observe the hoist load cell while *

liftig fuel assemblie This condition was brought to_the attention of the

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senior operator who counseled the operators. Subsequent observations *

determined that the operators' attentiveness to the load cells _was acceptabl I

Fuel loading was interrupted for a short period of time during the performance  ;

of Unit 1 Surveillance Test OPT-488A slave relay tes Surveillance  !

Test OPT-488A tests Relay 1-K6028 which trips power to 480V Motor Control  !

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Center (MCC) XEB4-1. The MCC feeds approximately one-half of the lighting, I the new fuel elevator, and the fuel building bridge cran In preparation for the test, the power for MCC XEB4-1 was transferred-from Unit 1 to Unit i When the test was perfermed, MCC XEB4-1 was-unexpectedly de-energized. Review ~j of the slave relay wiring diagrams showed that MCC XEB4-1 will be de-energized- '!

by Relay 1-KL602B (or 2-K6028), irrespective of which unit is supplying power j

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to i However, Surveillance Procedure OPT-488A did not contain any ,

information relative to this condition. No fuel movement was in progress at the time and Unit 2 initial core loading activities were not adversely l affected by this even j

.1 Review of control room logs and. shif t supervisor logs revealed that this  !

dnexpected occurrence had not been documented. Furthermore, at the conclusion  !

of this reporting period, no deficiency <iocumentation or procedure change had j

- been initiated to incorporate this note or warning that performance of this i surveillance test might have an adverse effect on fuel movement activitie :

F Subsequently, the licensee initiated a ONE form to address this issue and j l implement appropriate procedure changes, j On February 5,1993, at 11:15 p.m., a control circuit card failure halted l fueling activitie No fuel movement was in progress at the time of the i failure. The licensee determined that.there were no spare circuit cards  !

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available and the decision was made to remove the circuit card f rom the Unit I fueling machine and install it in the Unit 2 fueling machine. The card replacement was accomplished, the Unit 2 fueling machine wa.s declared operational, and fuel loading was resumed at 11:27 a.m. on February 6,199 No further interruptions were experienced for the remainder of the fueling ;

operation, and the last fuel assembly was placed in the reactor vessel at approximately 11:45 p.m. on February 7, 199 ,

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4.2 Conclusions

The inspectors considered the licensee's fuel loading performance to be good and noted that activities were performed in a controlled, deliberate manner ,

with a clear emphasis on attention to detail and safety. Licensee personnel appeared knowledgeable of the fueling activities and performed in a professional manner. A weakness was identified in Unit 1 Surveillance :

Procedure OPT-488 ,

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5 STARTUP TEST WITNESSING (72300,72302)

5.1 Reactor Trip System Test  ;

During this reporting period, the inspectors reviewed Startup Test ,

Procedure 150-015B, Revision 0, " Reactor Trip System Test." The purpose of this review was to confirm that the applicable Final Safety Analysis ,

Report (FSAR) commitments were properly addressed and that the procedure was consistent with the format specified in ANSI N18.7 and Regulatory Guide 1.6 ,

Additionally, the inspectors witnessed selected portions of this test which !

demonstrated, in part, the proper operation of the reactor trip system parameters, including the operational testing of the reactor-trip bypass l breaker ,

Based on the results of this review, no deficiencies were identified and it was determined that the applicable reactor trip system functions specified in :

FSAR Table 14.2-3 were appropriately incorporated into the objectives of this l procedure. It was also concluded that the programmatic requirements of .

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ANSI 18.7 and Regulatory Guide 1.68, including the provisions for definitive !

test objectives and acceptance criteria, pertinent prerequisites and initial ,

test conditions, and data acquisition, were appropriately reflected in the- !

technical and administrative portions of Procedure ISU-015 l

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pretest briefing and determined that all of the specified prerequisites were !

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properly performed and that the applicable precautions and limitations were correctly established, including provisions for monitoring source _ range count ;

levels. Throughout the conduct of this- testing evolution, command and control- ;

functions were effectively demonstrated and communications were determined to '

be excellent. No test discrepancies were identified and, based on the observed activities and the review of completed test documentation, it was i determined that all aspects of this initial startup test were effectively i accomplished in a well controlled manne :

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5.2 Cold Control Rod Operability Testing l

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The inspectors observed portions of the control rod operability testing j conducted in accordance with Procedure ISU-026B, Revision 0, " Cold Control Rod- :

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Operability Testing." The portion of testing observed involved control rod-

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drive mechanism operability checks and digital rod position indication (DRPI) l verification of control bank control rod positions. The inspectors verified  !

that the test equipment utilized during this evolution was operational and calibrate ,

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The inspectors also attended the pretest briefing conducted by the lead test engineer. The briefing was thorough and included discussions of prerequisite l conditions, precautions, and limitations associated with the test and expected !

actions and manipulations. All personnel directly involved in test I

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performance or plant operation were in attendanc !

l Throughout all observed testing and control rod movements, engineers from l Performance and Testing were in constant communication with the control roo .:

Constant communication was necessary because, as the rods were manipulated,. l their responses were recorded by a visicorder on recording paper (strip trace) l and analyzed. These strip traces provided the definitive determination in -

whether or not control rods responded as designed. The DRPI _ system was also ;

used as an indication of control rod movement. However, on two occasions,-the

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DRPI system indicated incorrect control rod position, but the strip traces for these two control rods indicated that the rods had functioned as desire :

These anomalies were recorded in the test log as DRPI system. failures and the !

test was continued. The analysis consisted of verifying the current responses j from the lift, stationary gripper, and moveable gripper coils. Acoustic _ l 4 signals from the control rod under test were also analyzed. Additionally, the :

, analysis also compared trace amplitudes and timing of on-off events with I previous trace readings. The actual strip traces were-then compared with expected traces from Westinghouse Technical Manual CP-0001-042, * Magnetic Control Rod Drive Mechanism for full length Control _ Rods." All strip _ traces-observed by the inspector were very similar to the expected values. After analyzing the data, Performance and Testing made the determination that the strip traces were acceptabl t The inspectors concluded that this portion of testing was well coordinated and i controlled. Communication between the test point and control- room was excellent. Test engineers were knowledgeable of the test and test procedures -i and conducted this portion of testing in a deliberate and professional manne .3 Conclusions Based on the review of Procedure 15U-0158, no deficiencies were identified, j and it was determined that the applicable requirements of Section 14 of the FSAR regarding the functional testing of the reactor trip system parameters were properly addressed. It was also concluded that the technical and administrative portions of this procedure were consistent with the format specified in ANSI 18.7 and Regulatory Guide 1.6 'l r

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The station maintenance activities affecting safety-related systems and components listed below were observed and documentation reviewed to ascertain that the activities were conducted in accordance with approved work authorizations, procedures, Technical Specifications, and appropriate industry codes or standard .1 Reactor Vessel Head Installation (Work Order 1-92-031115-00)

On February 9,1993, the inspectors observed the installation of the reactor'

vessel head. This maintenance activity was performed in accordance with'

Procedure MSM-CO-9901, Revision 2, " Reactor Vessel Head Removal and Installation." Cleanliness control in and around the refueling cavity was properly established in accordance with Procedure STA-607, Revision 13,

" Housekeeping Control." Personnel and equipment accountability was maintained using a personnel accountability log and a material / tool accountability lo Prior to the installation of the reactor vessel head, the inspectors observed quality control personnel examining the reactor vessel flange seating surface for cleanliness and to ensure the surface had no raised metal or burrs. As determined by the inspectors, the reactor vessel stud holes had been previously inspected by quality control personnel. In addition, maintenance personnel cleaned reactor vessel head surfaces prior to installation. Stud Holes 12 and 44 were clearly marked to facilitate accurate alignment of these holes with the alignment pin ;

The reactor vessel head installation was properly coordinated and execute l The individual stationed to monitor the load cell indicator during the lifting :

and lowering of the head maintained communications with the polar crane ,

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operator. Reactor vessel head Stud Holes 12 and 44 were properly aligned with l the alignment pins and observers closely monitored the lowering of the head to 3 ensure the proper engagement of the control rod shafts, conoseal thermocouple !

probes, and reactor vessel level indication system probes with their appropriate guide funnel :

6.2 Emergency Diesel Generator 2-01 Work Week Outage  ;

The inspectors observed the following maintenance on Emergency Diesel j Generator 2-01:  ;

i e Work Order 1-93-035429-00 repaired a lube oil leak on the lube oil i strainer outlet flang The work was performed under l Clearance 2-93-0096 l

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• Work Order 1-93-040373-00 was conducted to perform a visual inspection of the right bank idler gear as requested by the manufacturer. The work was performed under Clearance 2-93-0096 * Work Order 3-93-328213-01 replaced the desiccant Air Dryer 2-02. The desiccant was removed and new desiccant was installed using Procedure MSM-CO-3354, Revision 1, " Emergency Diesel Engine Starting Air Drye r. " The technicians also used Procedure MSM-G0-0203, Revision 3,

" Flange Alignment and Fastener Torque Data," to reinstall the system pipe flange No deficiencies were identified during the conduct of these maintenance activities and the inspectors verified that the work orders had been properly placed on the clearance, that technicians followed the work order instructions and procedural steps, and that good mechanical work practices were exhibite .3 Maintenance on Valve 2-8809B The inspectors also observed portions of the maintenance activity associated with Work Order 1-93-039628-0 Specifically, these activities included blue checking of the newly installed disc to seat mating surface and the installation of strain gauges on the valve stem. The observed activities were performed in accordance with the referenced work order, and appropriate controls were established for maintaining work area and system cleanliness and tool accountability. No deficiencies were observed, and it was determined that this activity had been effectively implemente .4 Conclusions All of the maintenance activities observed were appropriately performed with good work practices employed, good self-verification techniques applied, and ;

good procedural adherenc {

7 OBSERVATION OF SURVEILLANCE ACTIVITIES (61726) l 7.1 Remote Shutdown Operability Test l

.t On March 2, 1993, the inspectors witnessed selected portions of the {

performance of Surveillance Test Procedure OPT-216B, Revision 0, " Remote }

Shutdown Operability Test." Specifically, the inspectors observed the conduct i of Section 8.9 of this procedure, which verified the operability of the !

residual heat removal (RHR) system control functions at the remote shutdown j panel in accordance with Technical Specification 4.3.3. !

The. inspectors reviewed _the _ reference procedure as well as the associated Surveillance Work Order 5-92-503219AA and determined that the required administrative approvals and system tagouts had been completed and that the i specified prerequisites and precautions had been_ implemented. The inspectors r also witnessed the pretest briefing of the operations personnel who performed i I

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i this activit Based on these observations, it was determined that the I operations personnel were properly advised of the expected test parameters, i including operator functions and abnormal responses. Additionally, all !

aspects of the checklist for high risk and infrequent. evolutions prescribed in j Procedure ODA-407, Revision 4, " Guideline on Use of Procedures," were properly j articulate ;

P The inspectors witnessed the control testing functions of the RHR system at ]

the remote shutdown panel, including the operability verification-of Flo Controller 2-HCV-0606A (RHR Pump 01 discharge to reactor coolant system i Loop 1). During the performance of Step 8.9.11 of this procedure, the i operator at the remote . shutdown panel identified a discrepancy in that the-controller for Valve 2-HCV-0606A opened the valve when turned in the clockwise direction, which was contrary to the note in the procedure. This discrepancy ;

was properly noted and a procedure change notice was subsequently initiated to - ;

correct this condition. The operation of this controller was addressed 'n i several additional operating procedures. The_ licensee initiated actions to !

review the additional procedures and generate procedure change notices as require ,

The inspectors also witnessed the operational testing of RHR Heat Exchanger 2-01 bypass flow control Valve 2-FCV-0618-and pressurizer spray Valve 2-PCV-455C at the remote shutdown panel. Based on the observation of l these activities, no additional discrepancies were identified and. the system l was properly retuti ed 'to service subsequent to the completion of this i operability verification test. Throughout the conduct of this surveillance i activity, operations personnel demonstrated a proper awareness of procedural i requirements, system status control, and self-verification technique l Communications and control functions were superior and test discrepancies were !

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properly identified.

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l 7.2 Auxiliar_y Feedwater Pump Surveillance l The inspectors observed the performance of Surveillance Test OPT-2068, "AFW System," Revision 1, on the motor-driven Auxiliary Feedwater Pump 2-02. The !

auxiliary operator performing the test's local manipulations appropriately i i referenced the procedure and coordinated the performance of'each step with the 'l control' room. Good self-verification techniques were displayed by the - (

operator prior to the manipulation of each component. Test data was recorded- j as required by the procedure, and all test equipment utilized were within the l appropriate calibration dates. Additionally, sound signature data was i recorded on Valve 2AF-0051 for the check valve reliability program. The test l flow valve, 2AF-0055, was verified closed by observing pump flow indication !

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decreasing to 0 gpm prior to securing the pump. The manipulated valves that j were under the locked valve program were verified to be locked in position ,

subsequent to termination of the tes j i

During the performance of this surveillance, the inspector observed three tags l attached to Valve 2AF-0249, the auxiliary feedwater pump suction relief ;

Valve 2-02, in addition' to the valve name tag. One tag was a warehouse tag j i

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identifying the componen One was a red tag that stated, " Caution: Remove all tape and adhesive residue from this component prior to installation." The ,

third tag was labeled as a repairable item tag and stated, "Do Not Use. .This l item to be repaired."

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The inspector informed the unit supervisor of the tag information on the valve. Subsequently, the auxiliary feedwater system engineer provided several ,

documents to the inspector regarding the relief valve in question The '

inspector reviewed Startup Work Package Z-15500, which performed bench testing of the subject valve; Startup Work Authorization 75804, which authorized the j

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installation of the valve following system flushing; and a Prerequisite Test XCP-ME-18, " Safety Valve and Relief Valve Inspection" data sheet. This review concluded that the valve had been properly tested and installed, but-  ;

i that the tags on the valve had not been removed following valve installatio The tags were subsequently removed and no additional similar tags were identified in either of the remaining auxiliary feedwater pump room >

7.3 Conclusions

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The inspectors concluded that the observed surveillances were conducted  !

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appropriately and in accordance with the licensee's procedures and program Personnel were knowledgeable of the procedures and attentive to identified procedural deficiencies. Good self-verification was demonstrated.by all [

personnel during test performance. One issue was identified regarding the l oreration of a flow control valve controller from the remote shutdown panel t and the accuracy of several procedures regarding controller switch operatio j i

8 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702) l (Closed) Violation 445/9216-01: Unsecured Licensee Designated Vehicle -;

i This violation involved the identification of an unsecured licensee designated vehicle within the protected area which was unattended with the motor running while not in us In order to evaluate the adequacy of the corrective actions associated with  !

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this event, the inspectors reviewed the licensee's response to this violation, which was contained in TU Electric's Letter TXX-92358 dated August 13, 199 *

As stated in this correspondence, the primary reason for this violation was l less than adequate comprehension of the procedural requirements on the part o :

the vehicle operator .

Accordingly, the licensee initiated office Memorandum TSEC 92115 dated {

June 15, 1992, which reaffirmed the requirements for the control of licensee designated vehicles and identified management's expectations.for compliance l with these requirements. Additionally . the licensee issued guidelines for the =

control of licensee designated vehicles which are provided to ' individuals who  !

request the use of these vehicles. The inspectors reviewed this office i

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memorandum and the procedural controls associated with the use of licensee

, designated vehicles delineated in Procedure STA-904, Revision 4, " Vehicle And l

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Material / Package Control." Additionally, the inspectors reviewed a selected sample of the training records associated with the control of vehicles inside the protected are Based on the results of these reviews, no discrepancies were identified and it was determined that the licensee had implemented appropriate corrective actions to address the identified violatio FOLLOWUP (92701) (0 pen) Inspection Followup Item 446/9260-04: Abnormal Operating Procedures (ABNs) Procedural Adequacy Verification As previously documented in NRC Inspection Report 50-445/92-60; 50-446/92-60, both technical and administrative errors were identified in various ABN In-response to this issue, the licensee initiated a comprehensive program to verify the adequacy of ABNs, which included comparison of nomenclature and descriptions used in procedures versus the terminology. used in the master equipment list and field walkdowns of equipment and systems. These procedural adequacy verification activities were divided into subsets of ABNs which would require confirmation prior to entry into Mode 6 (fuel handling, source range, etc.), Mode 4 (nuclear steam supply systems, fire protection, etc.), and Mode 2 (balance-of-plant systems).

In order to independently assess the adequacy of these corrective actions, the inspectors examined a selected sample of ABNs, which were included in the group designated for completion prior to entry into Mode Specifically, the inspectors accompanied operators during the field walkdowns of ABN-101, Revision 4, " Reactor Coolant Pump Trip / Malfunction"; ABN-106, Revision 2, "High Secondary Activity"; and ABN-805B, Revision 0, " Response to Fire in the Auxiliary Building or the Fuel Building." The observed portions of the walkdowns only verified those procedural steps which were to be performed outside of the control roo The inspectors noted minor discrepancies during the walkdown of ABN-101 and ABN-106. Each procedure contained several instances in which component nomenclature, as written in the procedural step, did not exactly match the wording on the component's label. The operators noted these discrepancies and annotated the procedure to reflect the differences. For those components

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whose location was not already identified in the- procedure, the operators annotated the procedure to reflect the location The walkdown of ABN-805B also revealed a number of minor differences between '

the procedure nomenclature and the nomenclature found on the component label In addition, more significant differences in nomenclature were noted which created the potential for an operator to operate the' incorrect breaker or not operate the breaker at al Several steps were identified in which the location description for breakers was incorrect. The operators annotated the procedure to reflect the observed discrepancies and initiated actions to

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resolve the discrepancies. No deficiencies were identified by the inspectors  ;

that were not concurrently identified by the accompanying operator ,

Additionally, the inspectors examined recent revisions to the following.ABNs  !

to determine if the administrative enhancements and technical corrections j identified during the licensee's review process had been properly .i incorporated:  ;

• ABN-101, Revision 4, PCN 9, " Reactor Coolant Pump Trip / Malfunction"  !

• ABN-305, Revision 3, PCN 6, " Auxiliary Feedwater System Malfunction"

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• ABN-501 Revision 3, PCN 4, " Station Service Water System Malfunction"

• ABN-502, Revision 3, PCN 12, " Component Cooling Water System  !

Malfunctions" r

• ABN-701, Revision 4, PCNs 4 and 5, " Source Range Instrumentation *

Malfunction"

• ABN-710, Revision 6, PCN 7, " Steam Generator Level Instrumentation Malfunction" ]

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• ABN-803B, Revision 0, PCNs 10 and 11, " Response to a Fire in the Control !

Room or Cable Spreading Room" -i i

e ABN-805B, Revision 0, PCN 1, " Response to Fire in the Auxiliary Building i or the fuel Building" -l

• ABN-806B, Revision 0, PCN 3, " Response to Fire in the Electrical and Control Building" l L

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• ABN-901, Revision 4, PCN 2, " Fire Protection System Malfunction" Based on the results of this review, no discrepancies were identified and it i was generally determined that the licensee's procedural adequacy verification i process associated with ABNs was being effectively implemented. This  ;

inspection followup item will remain open pending review of the ABNs required for entry into Mode ;

(0 pen) Inspection Followup Item 446/9302-04

Deferred Tests and Retests j

The inspectors determined that deferred preoperational test retesting  !

associated with the plant computer central processing unit usage time had been i completed prior to entering Mode 5 as committed to in TU Electric l Letter TXX-93051 dated January 25, 1993. The testing was completed on  !

February 2,1993, in accordance with Test Procedure PPT-TP-93B-3, " Plant ~ i Computer CPU Upgrade and Software Verification Deferred Test," Revision l The data was submitted to engineering for review following completion of i

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-16-testing activities. This inspection followup item will remain open pending review of the remaining deferred tests and retest SAFETY EVALUATION REPORT REVIEW AND FOLLOWUP (92719)

As documented in TU Electric Letter TXX-92502 dated October 27, 1992, because of a modification to the power supplies for the plant computer, which replaced the emergency response facility computer, Transformers T2C5-1 and T2C6-1 were to be removed from the Unit 2 cable spreading room. Additionally, Section 8.4.6 of Supplement 26 to the Comanche Peak Steam Electric Station Safety Evaluation Report documents this commitmen During this reporting period, the inspectors reviewed minor modification .

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Form 93-53 and the associated Design Change Notice DCN-5605, Revision 0, which directed the removal of Transformers T2C5-1 and T2C6-1. The inspectors also i reviewed implementing Work Order 1-93-036484, which removed the subject transformers and performed a walkdown of the Unit 2 cable spreading room to ,

confirm the completion of this work activit j

Based on the results of these documentation reviews and field inspections, no !

discrepancies were identified and it was determined that the licensee had i effectively implemented corrective actions associated with this issue for i Unit 2. It was also ascertained that the corresponding Unit I transformers !

are scheduled to be disconnected and removed from the cable spreading room *

during the third refueling outag Therefore, no further action is required within this are l

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ATTACHMENT 1 1 PERSONS CONTACTED 1.1 TO ELECTRIC M. Blevins, Director of Nuclear Overview W. J. Cahill, Jr., Group Vice President J..-W. Dnnahue, Manager, Plant Analysis S. L. Ellis, Power Ascension Manager T. L. Heatherly, Licensing Engineer T. A. Hope, Site Licensing Manager D. C. Kross, Unit 2 Operations Manager D. R. Moore, Manager, Maintenance J. W. Muffett, Manager of Technical Support and Design Engineering S. S. Palmer, Stipulation Manager C. L. Terry, Vice President Nuclear Engineering and Support 1.3 NRC Personnel T. P. Gwynn, Deputy Director, Division of Reactor Projects  !

J. L. Milhoan, Regional Administrator l The personnel listed above attended the exit meeting. In addition to the personnel listed above, the inspectors contacted other personnel during this ;

inspection perio i

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2 EXIT MEETING .

An exit meeting was conducted on March 5, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did [

not identify as proprietary any information provided to, or reviewed by, the i inspector !

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