IR 05000445/1985008

Insp Rept 50-445/85-08 on 850501-0731.No Violations or Deviations Identified.Areas Inspected:Human Engineering Deficiencies,Applicant Actions on Previous Insp Findings, Plant Tours & Plant Status

ML20135H748
Person / Time
Site:	Comanche Peak
Issue date:	09/16/1985
From:	Kelley D, Will Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135H745	List: IR 05000445/1985008 ML20135H744
References
50-445-85-08, 50-445-85-8, NUDOCS 8509240192
Download: ML20135H748 (10)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/85-08 Construction Permit: CPPR-126 Docket: 50-445 Category: A2 Applicant: Texas Utilities Electric Company (TVEC)

Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES)

Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted: May 1 through July 31, 1985 Inspectors d 1 L.' Kelley, Sbntjr Res/' dent 9/,r/h'

flatd Reactor Inspectof (SRRI)

U F.. Smith, Resident _ Reactor Date Inspector-(RRI)

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Approved: YN T. F. Westerman, Chief, CPSES Task f/' d's/tJ - -

Date Group Inspection' Summary Inspection Conducted: May 1 through July 31, 1985 (Report 50-445/85-08)

Areas Inspected: Routine,unannouncedinspectionof(1)correctedHuman Engineering Deficiencies, (2) applicant actions on previous inspection findings, (3) plant tours, and (4) plant status'. The inspection involved 150. inspector-hours by two NRC inspector Results: Within the four areas inspected, no violations or deviations were identifie EBR'

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DETAILS Persons Contacted Applicant Personnel

- * G. Counsil, Executive Vice President, Nuclear

• J. C. Kuykendall, Manager, Nuclear Operations

• C. H. . Welch, Quality Assurance Supervisor

• J. C.. Smith, Quality Assurance R. B. Seidel, Operations Superintendent

• R. E. Camp, Startup Manager

• S. M. Franks, Special Project.and Technical Support Lead

• R. Wistrand, Administration Superintendent

• J. J. Allen, Operations Engineer

• R. A. Jones, Manager, Plant Operations

• J. T. Merritt, Assistant Project General Manager L. G. Barnes, Operations Supervisor

• T. L. Gosdin, Support Services Superintendent

• D. W. Braswell, Engineering Superintendent

• M. R. Blevins, Maintenance Superintendent

• C. E. Scott, Manager, CPSES Startup

~*D. E. Deviney, Operations QA Supervisor

• R. T. Jenkins, Operations Support Superintendent E. Alarcon, Results Engineer P. G. Smith, Administrative Supervisor J. L. Brackney, Records Supervisor

• Denotes those present at exit interview The NRC inspectors also interviewed other applicant employees during this inspection perio . Verification of Correction of Human Engineering Deficiencies The Human Factors Control Room Design Review of CPSES, conducted by the Human Factor Engineering Branch of the NRC, identified Human Engineering Deficiencies (HEDs).

NRC Inspection Report 50-445/84-45 reported that, as of December 31, 1984, all but three prelicensing HEDs had been closed and that the remaining HEDs will be verified by the NRC resident inspectors and documented in future inspection report !

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-3-As. of July 31, 1985, two of.the three remaining HEDs have been verified by the NRC resident. inspectors as satisfactorily corrected by personal observation of the installed hardware. There is now one HED remaining to be close The following HED remains to be verified:

8 HED DESCRIPTION-Trend recorder scale differs from chart paper scal ACTION Confirmatory on recorders having paper matching recorder scales .(all recorders should have paper), including Hot Shutdown Panel (HSP).

For tracking purposes this shall be considered Open Item 8508-0 Note: HED 122 was closed with exception of " proper paper in recorders" which will be verified as a part of this HE The following HEDs have been completed and then verified by the NRC resident inspectors:

181. HED DESCRIPTION The nuclear instrumentation system recorder lacks a scale for differential powe ACTION Confirmatory on installation of a scale for differential powe . HED DESCRIPTION Counters require calculations by the operator when displayed values run past 60 minutes. Other counters require the operator _to convert-displayed values by multiplication factors other than a multiple of

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' Confirmatory on . full scale counters . replacing 0.5 scale' counters an -

' CPS-0 ' Applicant Actions on Previous Inspection Findings

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- (Closed) Unresolved Item 8424-01: During inspection of the completed data package for preoperational test ICP-PT-57-06, "RHR'ECCS-

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Performance," the NRC inspector noted that, while the Residual-Heat

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-4-Removal'(RHR) pumps were providing the water supply to the Centrifugal Charging Pumps (CCPs), the CCP local suction pressure gages 1-PI-187 and 188 were subjected to pressures in excess of their range. This required subsequent calibration checks to verify the gages had not been damage The applicant stated that the local gages are not used during actual ECCS performance and thus replacing them with a gage of higher range would not be necessary. During normal operation of the CCP it is appropriate to have a low range gage because the minimum suction pressure is less than 10 PSI Since the issue was raised, however, the' applicant has placed a memo in the surveillance test procedure file to ensure the gages are isolated to prevent overranging during surveillance testing. Since there'is no safety significance to this item, and followup action is at the option of _the applicant, this ' item does not require tracking by the NRC and is therefore close (Closed) Unresolved Item 8431-01: -During inspection of the completed data package for preoperational test ICP-PT-37-02, " Condensate Storage and Transfer System," the NRC inspector was unable to understand the justification for changing the tolerance applied to the acceptance criteria for condensate transfer pump total discharge head (TDH). The value was originally 200 feet, +5%,-0%.

This was changed to 200 feet +10 feet, -10 feet, which represents a degradation. The justification stated on the form was unclear and did not address the apparent degradation. The applicant has since produced a letter (GTN-66188) from the Architect-Engineer, Gibbs,&

Hill, stating that a plus or minus 5% tolerance can be applied to the nominal flow or TDH of a pump when testing with the system, because differences in piping configuration between the test stand at the factory and the actual installation can produce minor deviations from the pump performance curves, and that this does not represent a degradation. This information was added to the test data package thereby clarifying the justification for the tolerance change. This item is close (Closed) Unresolved Item 8431-03: During inspection of the completed data package for preoperational test ICP-PT-55-01, " Reactor Coolant System Cold Hydrostatic Test," the NRC inspector found no documentation of specific welds inspected, nor reference to such documentation. The applicant has since incorporated into ICP-PT-55-01 a supplement which explains that the satisfactory hydrostatic test results on the specific welds is filed separately in the Permanent Pla_nt Record Vault with other hydrostatic test inspections records, under Test Procedure ICP-PT-55-01. The NRC inspector has since verified that this file is in place, is

.auditable, and found no deficiencie This item is close . - _ . . -

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-5- (Closed) Open Item 8431-04: During an NRC review of the applicant's operations quality assurance program, the NRC inspector noted that the limited scope of the Operations Administrative Control and Quality Assurance Plan (OAC/QAP) appeared awkward in the case of design control as delineated in Section The OAC/QAP placed requirements'on the predecessor organization to TUGC0 Nuclear Engineering (TNE), then referred to as Texas Utilities Services, In (TUSI) even though that organization was outside the scope of the plan, as well as TNE. Revision 5 of Section 8.1 of the OAC/QAP, dated April 1, 1985, removed the reference to TUSI and now holds TNE

' within the purview of the pla Another factor potentially leading to confusion about the scope and

. applicability of OAC/QAP requirements was use of the terms

" safety-related," "important to safety," and '! quality related."

These terms were not defined in the OAC/QAP but were used throughout the plan in such a manner that they could be interpreted differently by different reader The applicant corrected this condition by ,

eliminating the term, "important to safety" from the plan and by providing revised definitions of " quality-related" and " safety-related" in Appendix 8 to the OAC/QA This item is close (Closed) Unresolved Item 8431-11: During'an NRC inspection of th applicant's OAC/QAP in Augustn1984, the NRC inspector observed a drill designed to demonstrate activities in the areas of maintenance, maintenance planning, documentation, records, procurement and quality control inspections. The subject of the drillLwas a simulated failure of a containment spray heat exchanger outlet motor-operated valve. The NRC inspector was unable to resolve the questions raised during the procurement related activities of the dril As of this inspection the issues have been resolved as follows, therefore, this unresolved item is closed:

(1) There were minor procedural discrepancies which had no safety significance. These have been ccrrected in subsequent revision (2) The nonformal training and. qualification program used for Administrative Department personnel with purchasing or procure-ment responsibilities was questioned. The. applicant's position as of.this followup-inspection is that self administered reading is adequate for the people involved, and they are responsible to perform their functions in accordance with current procedure It.is the supervisor's responsibility to ensure that this is don .

(3) In preparing the. mock parts' requisition'for the drill, the site QA inspector noted a discrepancy between.the component (motor)

nameplate and the applicable construction drawing. Proper

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-6-actions were taken by the applicant to correct the discrepancy, however, the NRC inspector was not aware of what actions were taken to ensure there were no similar problems. The RRI followed up and noted that a comparison was made between all motor operated valve nameplates and the drawings, in accordance with the disposition of CPSES Problem Report PR 84-283, dated August 27, 1984. This comparison yielded a total of 39 valves with a disparity between motor horsepower on the nameplates and motor horsepower shown on the drawings. Implementation of the corrective actirsn by the applicant has not been completed as of this inspection; as such this shall be tracked separately as Open Item 8508-0 f. (Closed) Unresolved Item 8431-13: During the August 1984, NRC inspection of the applicant's OAC/QAP, a review was conducted of the vault facilities and the records stored therei Some of the conditions found gave rise to questions which have since been resolved with the RRI and, therefore, this item is closed:

(1) Some of the station logs were drawn at random from the. vaul The NRC inspector noted that the dates of the logs were not reflected in the Master Records Index. The applicant's repre-sentative later explained to the RRI that, as required by STA-302 (Station Records),~the Master Records Index indicates the fact that the logs are stored in the vaul Each lon date is not required to be reflected in the Master Records inaex, nor-is it needed. All of the logs are stored in one area and, thus, are easily retrievabl (2) Records could not be retrieved from the vault in what the NRC inspector considered a timtly manner when' requested by noun nam The applicant later showed the RRI that each record has its own unique identifier and through the Master Records Index could be easily located and made available for. inspection. Noun name sorting of records in the Master Records Index is not as practical as the unique identifier and since the unique identifier is usually known by the person with a need to retrieve a specific record, the applicant has opted to continue using a unique identifier inctead of noun name sorts in the Master Records Index computer printout. The RRI did not see any problem with this approach, which also is not contrary to any applicable regulatory requirement (3) In August 1984, STA-302 defined the " Record File Index" as that '

index which, " . . . gives the specific record file location for all record types which are stored in the records center . . . "

The NRC inspector noted that this index did not fulfill the functions of giving specific location in the. vault, and no mapping diagram existed. The custodian interviewed at the time, however, knew exactly where requested records were locate .

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! During the followup inspection of this issue, the RRI noted that the latest revision (Rev. 7) of STA-302 redefines the Records File Index as "An index which gives the subfile method of filing all record types . . . ." This index indicates a location for 4 each record and acts as a backup index if problems occur with the computerized Master Records Index. .The applicant's Records

Supervisor stated that a floor plan showing file locations will be posted, though not required by procedure, at a later date when the construction and testing phase is completed and the files become more stati (4) During the August 1984, inspection the NRC inspector expressed concern that a large number of records were checked out for long periods of time with no indication of. expressed approval from the Records Supervisor, which appeared to be contrary to the intent of.STA-302, paragraph 4.9.3. The Records Supervisor explained to the RRI during the followup inspection that his approval _was often verbal, that they recognized more controls were needed and, thus, Revision 7 of.STA-302 requires a checkout form 302-5 to be signed by the Records Supervisor before any record is checked out. This appears to have solved the problem.

I (5) In-August 1984, the station records vaul't was observed to have~a temperature of 68 degrees Fahrenheit, a . relative humidity of 62%, and the recorder chart showed the humidity to have exceeded

! 50% for the preceding week. The applicant also had no procedural controls.in effect at the time which required the'

humidity and temperature to be controlled. During the followup inspection the RRI noted that the applicant had installed a

"Cargocaire" dehumidifying system which, since installation in June 1985, has maintained the relative humidity at approximately

.40% and the temperature below 70. degrees Fahrenheit, as indicated-on the recorder charts. STA-302 has been revised to require environmental conditions to be maintained in accordance with film manufacturer's recommendations. The applicant had sample films inspected by the manufacturer for damage that might have been caused by failure to maintain the relative humidity as required by ANSI.N45.2.9-1974,.and found no problem The applicant's representative stated that the film manufacturer had no concerns about film storage at CPSES because of the dry

' climate in this geographic locatio ^ (Closed) Open Item 8436-03: This was an open'NUREG-0797' confirmatory

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issue where the applicant had redesigned the logic to preclude blocking of- f.ne ESFAS signal, upon reset of the high radiation signal, but new design had not been confirmed by testing. This testing was incorporated into ICP-PT-57-10 (Rev. 2), " Load Group Assignment Test," by a change (TPD No. 47) initiated on January 18, 1985. The NRC inspector reviewed the completed test data package for ICP-PT-57-10 and noted that the-test was satisfactorily completed on January 19, 1985. 'This item is. close .. .-, -. , -,

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h. (Closed) Open Item 8439-01: During review of System Operating Procedure SOP-101A, Revision 1, " Reactor Coolant System" the NRC inspector noted discrepancies between the initial valve lineup sheets of Attachment 1 and the procedure text. These were subsequently corrected by revision of the procedur Revision 3 of 50P-101A was reviewed during this inspection. The NRC inspector verified that all discrepancies identified by this item had been corrected and noted no further problems with the procedure. This item is close i. (0 pen) Unresolved Item 8431-06: During a review of selected Main-tenance Action Requests (MARS) documented in NRC Inspection Report 50-445/84-31, the NRC inspector identified two minor deficiencie '

The deficiencies were:

(1) Cross-outs were not initiated on Startup Work Authorization (SWA) No. 21269, which was appended to MAR 84-2017. This placed the authenticity of the document in questio (2) The classification section of MAR 84-1516 was not filled out; i.e., emergency, 24-hour, or regular, as required by MDA-103,

" MAR Processing-Maintenance Department."

The SRRI conducted a followup inspection to verify resolution of this item, and noted that the applicant issued deficiency report DR 85-055 which corrected the omission on MAR 84-151 However, action to resolve the questionable entries in SWA #21269 had not been complete Recent audits conducted by the applicant have revealed a similar weakness in the procedural control of record generatio Cross-outs, obliteration of errors, and failure to indicate that blank data entries were not applicable, were found. This indicated the need for a station administrative procedure revision and appropriate training such that quality records will be maintained authentic and auditable. The applicant told the RRI that a revision to STA-302, " Station Records," is in process to correct this weakness. This item will remain open until resolved during a later inspectio j. (0 pen) Unresolved Item 8431-09: An_ inspection of the applicant's operational design control program, documented in NRC Inspection Report 50-445/84-31, revealed that the station and engineering department administrative procedures (STAS and EDAs) did not address the ~ prerequisites for-installed modifications to plant operation These prerequisites include:

(1) Drawing update (2) Procedure revision-(3) Training (4) Test deficiency resolution (5) Spare parts considerations

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-9-The applicant has issued revisions to the STAS and EDAs that address

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operational design control. The NRC inspector reviewed STA-701, Rev. 2, " Station Modification _ Control," and EDA-205, Rev. 3, " Modi-

fication Implementation," and noted that the procedures did not adequately address the assessment of modifications with respect to

, operator training. _Also noted was the lack of a definite description of what a completed modification package should contain. The proce-dures, as they were written during this follow-up inspection, did not contain a check-off sheet or other mechanism to insure that all required aspects concerning a design modification have been complete This item will remain open pending final resolution during a subse-quent. inspectio '

No violations or deviations were identifie . Plant Tours During this reporting period, the SRRI and RRI conducted inspection' tours of Unit In addition to the general housekeeping activities and general cleanliness of the facility, specific attention was given to areas where safety-related equipment was installed and where activities were in progress involving safety-related equipment. These areas were inspected to ensure that:

. Work in progress was being accomplished using approved procedure . Special precautions for protection of equipment were implemented and additional cleanliness requirements were being adhered to for maintenance, flushing, and welding activitie . Installed safety-related equipment and components were being protected and maintained to prevent damage and deterioratio Also during these tours, the SRRI and RRI reviewed the control room and shift supervisors' log books. Key items in the. log review were:

. Plant status

. Changes in plant status

. Tests in progress

. Documentation of problems which arise during operating shifts No deviations or violations were identifie . Plant Status as of July 31, 1985 Unit No. 1 has been 99% complete, however, excavation is underway to facilitate replacement of main condenser internals, and an evaluation-is being performed of piping _ support .

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-10- Replacement of the hydraulic operators of the Main Steam Isolation Bypass valves with manual operators is completed. Supporting FSAR, Technical Specification, and procedure changes are in proces The following~ items related to NRC resident operations office findings are open pending. applicant action and NRC; followup inspection to confirm completion for closure:

Violations 8 Deviations 0 Open Items 92 Unresolved 10 Total 110 Action is underway to complete these items, Closure will'be documented in future inspection report Unit No. 2 is 75% complete. The preoperational test program on-systems associated with NRC inspections has not yet starte . Fxit Meeting An exit interview was conducted August 7, 1985, with applicant repre-sentatives identified in paragraph 1. During this interview, the operations resident inspectors reviewed the scope and discussed the

, inspection findings. The applicant. acknowledged the2 finding .

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