ML19332D190
| ML19332D190 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/16/1989 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-89-200, NUDOCS 8911300131 | |
| Download: ML19332D190 (8) | |
See also: IR 05000445/1989200
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UMTED STATES -
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' NUCLEAR REGULATORY COMMISSION
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' November.16, 1989
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- Docket: No.: 50-445:
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.Mr. W.- 1 Cahill, Jr.
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Executive Vice' President-
-Texas Utilities: Electric
1.400 North Olive Street, Lock Box 81
Dallas, Texas 75201;
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Dear Mr. Cahill:
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SUBJECT: NRC: INSPECTION REPORT 50-445/89-200
COMANCHE PEAK OPERATIONAL
READINESS ASSESSMENT TEAM INSPECTION-
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' An announced special' team inspection' of the Comanche Peak Steam Electric
. Station was. conducted by the NRC Headquarters staff during the' period of
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0ctober 16-27,c1989.' The purpose of this inspection.was to provide the-
. Director of the Office of Nuclear Reactor Regulation.with an independent-
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assessment of the construction and operational status of your facility.
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The'0perational-Readiness Assessment Team (ORAT) inspection concluded that
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the construction and testing lof the plant was not sufficiently complete to make
La determination withl respect to operational readiness.
Consequently, the team
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held an' interim-~ exit with you and members of your staff on October 27, 1989,
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-and will-schedule a follow-up inspection visit in the future. This: letter
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. documents the team's-. conclusions,-and'the1 concerns identified during the interim
exit that require your: attention before the follow-up. inspection.
This letter
~does not detaillany of.the strengths identified by the inspection team. A
discussion of the inspection findings will be provided in Inspection Report
50-445/89-200,- which will be issued following the completion of the remainder
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of the inspection.
The inspection team concluded that an insufficient number of systems were in
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the ' direct operational control of the operators to support a valid assessment
of operational readiness.
In addition, the team concluded that the plant
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staff had not adequately assumed responsibility for the systems and areas under
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operational control, and had not fully implemented operational programs.and
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= procedures as a direct result of the large amount of remaining construction and
maintenance work.. Finally, the team concluded that the operations and
operations support programmatic readiness were not adequate because several
operational programs had not been implemented or had weaknesses which precluded
their effective implementation.
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8911300131 891116
ADOCK 05000445
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Mr. W. - J.' Cahill, ' Jr.
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Novamber 16, 1989
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- As we discussed with you and your staff, our inspection activities resulted in
a clearer definition of the expectations regarding the level of construction
completion required for issuance of the operating license and a more detailed
assessment of the progress of your remaining work activities.
In addition,
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Lthe meaning and purpose of the operational readiness period was clarified.
As discussed during the interim exit, several actions must be taken before the
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remainder of the inspection can be completed.
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Evaluate and resolve the specific concerns identified by the inspection
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team and listed in Enclosure 1.
In addition, perform a broad-based
assessment of the~ adequacy and implementation of all of your programs
to identify and resolve any similar deficiencies.
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2.
Based on the minimal previous comercial experience levels of your
'mid-level managers and. licensed operating staff, take steps to:
a.
Reduce the maintenance backlog and ensure that all systems are
functional for power operations.
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b.
Evaluate augmentation of the management staff with experienced
personnel,
c.
Focus attention on plant-labeling adequacy by examining the status of
the present plant labeling and evaluating the need for immediate
corrective actions, and by committing to implementing labeling
upgrades before the completion of the first refueling outage.
3.
The remainder of the ORAT inspection will be performed after you have:
a.
Demonstrated that all systems can function by the successful
performance of all technical specification surveillance tests that
are required for 5 percent power operations--to the extent they
can be performeo before fuel load,
b.
Decided that the facility is operationally ready for low power
operation, including completion of the items above, and advised the
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NRC that the facility is ready for the team to return and confirm
your operational readiness assessment.
Sincerely,
77/. W L /
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DennisM.Crutchfield, Ass 7cIitteDirector
for Special Projects
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Office of Nuclear Reactor Regulation
Enclosure:
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Identified Concerns
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'M . W. J. Cahill
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November 16, 1989
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cc w/ enclosure:
Mr. Robert F. Warnick.
Jack R. Newman, Esq.
Assistant Director
Newmr.n & Holtzinger
- for Inspection Programs
1615 L Street, NW
Comanche Peak Project Division
Suite 1000
.U. S. Nuclear Regulatory Connission
Washington, D.C.
20036
P. 0, Box 1029
Granbury, Texas 76048
Chief, Texas Bureau of Radiation Control
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Texas Department of Health
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Regional Administrator, Region IV
1100 West 49th Street
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U. S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
Honorable George Crump
County Judge
Ms. Billie Pirner Garde', Esq.
Glen Rose, Texas 76043
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Robinson, Robinson, et al.
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103 East College Avenue
Appleton, Wisconsin 54911
Mrs. Juanita Ellis, President -
Citizens Association for S'ound Energy
1426. South Polk
Dallas, Texas: 75224
E. F. Ottney
P. O. Box 1777
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Glen Rose, Texas 76043
Mr. Roger.D. Walker
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Manager, Nuclear Licensing
Texas Utilities Electric Company
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400 North Olive Street, L. B. 81
Dallas, Texas 75201
Texas Utilities Electric Company
-c/o Bethesda Licensing
3 Metro Center, Suite 610
Bethesda, Maryland 20814
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William A. Burchette, Esq.
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Counsel for Tex-La Electric
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Cooperative of Texas
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Heron, Burchette, Ruckert & Rothwell
1025 Thomas Jefferson Street, NW
Washington, D.C. 20007
GDS Associates, Inc.
Suite 720
1850 Parkway Place
Marietta, Georgia 30067-8237
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!DATEJc:11/07/89
- 11/07/89
- 11/07/89
- 11/07/89
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ENCLOSURE 1
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CONCERNS. IDENTIFIED DURING INTERIM INSPECTION EXIT OF OCTOBER 27, 1989
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1.
Unidentified hardware deficiencies
Numerous hardware deficiencies were
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1 dent 171ed in systems and rooms which had been turned over to operational
control. These deficiencies had not been i nntified during the room and
. system turnovers, and had not been identified by the operators or system
_ engineers during routine tours and surveillances.
For example, the _ inspection team identified (1) leakage of the IB Diesel
Generator (DG) jacket water and service water piping joints, and
_(2)' standing water, loose relay label plates, and broken terminal board
wire retainers in DG. control cabinets. The IE battery cells had
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electrolyte levels above high level marks and showed evidence of
overfilling. - There were-invalid Quality Control Nonconformance report
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waiver tags. posted on equipment which had not been removed nor identified
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during(CS) service water relief valve, tapt
room and area turnovers. The team Ound a leaking Containment
Spray
blockage of the CS flow
transmitter drain line, a disconnected limit switch on valve HCV-0606,
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and removed safety injection accumulator spool pieces without procedural
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guidance.
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Throughouttheplant,theteamnotedthat(1)theelectricaldistribution
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and process-instrumentation doors under operational control were not
routinely secured by(3)perations, (2) the vent and drain valve caps were
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not installed, and
several rising stem valves had water and debris in
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the top of the actuator which could adversely affect the operation and
reliability of the valves.
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2.
Operational Responsibility - The actions of a licensed operator inoicated
a _ lack of " ownership" for the operational consequences of conflicting
testing requirements, in that the operator was persuaded by maintenance
technicians to simultaneously perform two surveillances which he believed
conflicted.
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Shift Communications - The team observed a lack of effective comunication
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between operating shifts concerning the corrective and troubleshooting
actions following problems encountered turning the main generator.
4.
System Status Control - ODA-410. " System Status Control," provided a
method for recording the current system valve alignments and maintaining
configuration control of all operational systems. A review of the DG
system identified that the valve status file was not being updated as
required, in that the position of DG starting air isolation valves was not
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correctly updated on the drawing. Although the use of marked-up drawinct
is a difficult method to implement, the valve alignments of only four
systems were being controlled by the procedure.
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LCO Tracking and Control - ODA-308, "LC0 Tracking Log," provided a method
for tracking and control of LC0 action requirements. The procedural
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requirements were not correctly implemented in that the entry and exit of
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LCOs were not logged, and the shift technical advisor reviews of recent
LCO action. requirements were not performed.
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Plant Investigation Reports - STA-503, " Plant Investigation Report,"'
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provided for identification.and tracking of PIRs in order to obtain timely
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and effective implementation of corrective actions for plant events.- This
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program was not properly implemented and-the corrective actions were not
~ timely or effective because (1) immediate corrective actions were not
being recorded, (2) PIRs were not initi.ated for problessiconcerning the
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main generator turning problems as indicated by the shift log, (3) the
operations department believed that PIR closure could occur when correc--
tive actions.were identified vice implemented, and most importantly (4) 23
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outstanding PIRs were overdue on October 20, 1989, by as much as
1-4= months and 4 PIRs on inadequate clearances as!early as April 1989 had
not been evaluated.
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7.
Corrective Actions for NRC Inspections - There were several' corrective
actions which remained to be completed for previous NRC inspection find-
ings. For example, the team noted that 159 of the original 238 discrep-
ancies between the emergency response guidelines and the facility's design
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basis remain to be resolved prior to fuel load.
in addition, the team
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noted that the corrective actions to resolve the accessibility and opera-
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bility of equipment in the AFW turbine feedwater pump. room'had nct identi-
fied or resolved concerns involving (1) inadequate grating installed to
access pquipment, (2) excessive turns required to operate valves,-and (3)
inadequate-room ventilation.
~8.
Confined S) ace Entries - STA-606, " Work Requests and Work Orders,"
' requireo t1at a confined space work permit be issued prior to beginning
work in any confined space.
The team noted that work was secured on the
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outboard containment isolation valve for the containment spray system;
however, the confined space was-not secured (i.e., closed or posted)
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following the completion of this work.
9.
Design Modifications - STA-205, " Changes to Procedures," and STA-717,
. Design Modification Review Group," procedurally allowed modifications to
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be performed without a safety evaluation if the modification was performed
prior to fuel load. The applicant had performed safety evaluations for
all modifications and intended to incorporate all modifications as a final
safety-analysis change prior to fuel load; however, the potential existed
to miss evaluating a change to the facility.
In addition, STA-205 did act
require a safety evaluation or screening for typographical errors or for
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non-significant changes of intent. This ambiguous requirement had the
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potential to miss safety evaluation for omitted symbols such as +/- signs
and required individual interpretation as to the intent of the procedure.
10. Limiting Conditions for Operation Tracking - ODA-308, "LC0 Tracking Log,"
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did not require document #. tion of management authorization for voluntary
LC0 entries, verification of the required periodic management reviews, and
docunentation and retention of the rationale for LCO exits.
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. Root Cause Analysis and Trending - The system engineers minually performed
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data reduction and-trending-of component root ~cause failure. This method
-was time consuming and difficult to perfom because the nuclear plant
reliability data system (NPRDS) was not fully implemented and had numerous
component identification differences with the master equipment list.
12.
Inter-system Actuations - STA-606, " Work Control Procedure," did not
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require notes or precautions to specifically identify to the operators
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anticipated ' inter-system actuations such as alarms or trips which may
occur during planned work activities.
13. Timely Incident Investinations'- STA-422 " Processing of One Forms," did
not: support an expeditious initiation of incident investigations because
the one form must be processed through the work control center and plan of
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the day meetings before the. incident team is formed.
14.
Post-Trip Reviews - ODA-108, " Post-Trip Review," assumed that all trips
nad a cettnitive cause and did not provide for additional evaluations of
those. trips which cannot be definitively identified prior to restart of
the facility.- In addition, the procedure did not require timely. written
statements of the principals involved in a trip in order to document the
circumstances before memories fade.
15. . Plant Labelino - An upgrade program to improve the useability of the plant
labelingthroughouttheplanthadnotbeen'inglemented. The valves and
components were currently labeled with metai dog tags" which were very
difficult to locate and use.
In addition, rooms and commodities (i.e.,
trays, conduits, and piping)-were not currently labeled throughout the
plant. The implementation of this upgrade program had been delayed until
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completion of the'first refueling outage (and may not be finished by
then).
Because of the difficulty in finding and reading the present
labels, a potential exists for operator errors.
16. One Forms - STA-421, "One Form Evaluation," provided a new method for
identification and resolution of plant deficiencies and had not been
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This program was intended to consolidate and simplify th
several problem identification methods.
17.
Safety Evaluations - STA-602, "Temporar,y Modifications," did not require a
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safety evaluation of~ temporary modifications which were performed before
fuel load. The applicant was performing temporary modifications without
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safety' evaluations and intended to reduce the number of outstanding
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temporary modifications, and perform safety evaluations of the remainder
-at th4 time of fuel load. Although acceptable, this method had the
potential to miss performing the required safety evaluations.
18.
Preventive Maintenance Programs - All of the periodic preventive mainte-
nance requirements were not being performed due to the large construction
and maintenance work load. As a result, the PM backlog was increasing.
19. Scaffolding - CMP-CV-1014, " Scaffold Erection and Control," which con-
trolled scaffolding erection over safety-related and seismic equipment
.during the operations phase, had not been implemented.
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" * 20. frevious Coasnercial Experience - Although the licensed operators met the
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minimum expertence requirements of the applicent's program for hot partic-
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1pation experience, the operators had minimal previous commercial operat-
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ing experience.
In addition, the mid. level managers in the areas of
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operations, technical support, plant evaluations, radiation protection,
and fire protection, also had minimal previous comercial operating
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experience. Although the ANSI 3.1 requirements for minimal experience
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levels had been met, the lack of depth of commercial operating experience
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in sanapers and operators will make a smooth initial startup wore
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difficu.t.
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21. Procedural Inadecuacies - ABN-710A, "SG Water Level Instrument Malfunction
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Chect," had referencing inadequacies which had the potential to confuse
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the operators and result in a trip of the reactor. All of the operators
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questioned incorrectly identified the steam generator protection bistables
due to confusing references in the procedure.
In addition, there were
unauthorized and unreviewed temporary markings on the instrument cards
which incorrectly identified the level switch numbers. Although correc-
tive actions for previously-identified procedure problems had been imple-
mented for this procedure, this potential e-ror was not identified.
22. Cualit.y Assurance involvement in 0)erations - Discussions with the
Operations Manager indicate that tte Quality Assurance Department had not
been used for the identification and resolution of operations problems.
In addition, the Quality Assurance Department had_not performed an audit
of the technical specification (TS) surveillance scheduling program, but
did intend to review this master schedule of the TS required testing prior
to fuel load. During a limited review, the inspection team identified
four errors in the master schedule where required TS surveillances were
not scheduled. The lack of Qus11ty Assurance Department involvement in
the support of management overview of the operations department and
-operational programs was not indicative of a pro-active approach to
quality involvement in the support of operational rndiness.
23. Technical Specification Surveillance Procedures - The trigger procedures
(i.e., shift logs) fcr conditional T5 surveillance requirem a ts allowed
missing hourly primary and secondary temperature and pressure readings due
to the longer frequency of the trigger procedures.
In addition, the TS
surveillance requirements for localized containment temperatures were not
specifically obtained by the surveillance procedure.
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Clearance Procedures - STA-605, " Clearance and Safety Tagging," allowed the
shift supervisor to remove a danger tag and reposition or operate equip-
ment on a temporary basis in nonemergency conditions without sufficient
controls to ensure the adequacy of the remaining clearance.
This is
particularly safety significant at this f acility due to the extensive use
of master clearances and tiered clearances.
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