ML20141P063

Operations Insp Rept 50-445/85-14 on 851001-31.Violation Noted:Failure to Maintain Sufficient Chemistry Records

ML20141P063
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1986
From:	Barnes I, Kelley D, Will Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141P047	List: ML20141P046 ML20141P053 ML20141P054 ML20141P063 ML20141P072 ML20141P077 ML20141P083
References
50-445-85-14, NUDOCS 8603180506
Download: ML20141P063 (12)

See also: IR 05000445/1985014

Text

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APPENDIX C

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OPERATIONS INSPECTION REPORT

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U. L S. NUCLEAR' REGULATORY COMISSION ?

REGION IV

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CPPR-126

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u ' NRC, Inspection Report:

50-445/85-14

Permit:

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50-445

Category:

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Aphlicant:

Texas Utilities Electric Company (TUEC)

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. Skyway Tower

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400 North Olive Street-

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Lock Box 81

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Dallas, Texas

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Facility Name:

Comanche Peak Steam Electric Station (CPSES), Unit 1

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Inspection 'At:

Glen Rose, Texas -

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Inspection. Conducted:

October 1-31, 1985

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' Inspectors

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D.

.'Kelley,SeQTbr

ent Reactor Inspector Datd /

. SRRI),i Region /IV C

Group

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(paragraphs 1,5, 7f )

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W. F. Smith, Resident Reactor Inspector (RRI)

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Region IV CPSES Group

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(paragraphs 1, 2, 3, 4,:5, 6, 7, 8)

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Reviewed By:

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I., Barnes, Group Leader, Region IV CPSES Group

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' Approved:

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T. F.4 Westerman, Chief, Region,IV CPSES Group

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inspection Summary

Inspection Conducted:

October 1-31. 1985(Report 50-445/85-14)

Areas Inspected:

Routine, unannounced inspection of (1) applicant actions on

previous inspection findings, (2) maintenance procedures, (3) preventive

maintenance programs, (4) plant tours, and (5) plant status.

The inspection

involved 117 inspector-hours onsite by two NRC inspectors.

Results: Within the five areas inspected, one violation (failure to maintain

suf ficient chemistry records, paragraph 4) was identified.

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DETAILS

1.

Persons Contacted

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Applicant Personnel.

• A. B. Scott, Vice President Operations

• J. C. Kuykendall, Vice President

• C. H. Welch, Quality Control Services Supervisor

• R. B. Seidel. Operations Superintendent

5. N. Franks, Special Project and Technical

Support Lead

• M. R. Blevins, Maintenance Superintendent

D. E. Deviney, Operations QA Supervisor

• R. A. Jones, Manager, Plant Operations

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K. L. Luken, Lead Startup Engineer

• R. R. Wistrand, Administrative Superintendent

• D. W. Braswell, Engineering Superintendent

• J. C. Smith, Quality Assurance

• T. L. Gosdin, Support Services Superintendent

• G. M. McGrath, Licensing / Compliance Supervisor Startup

• H. J. Riggs. Operations Support Engineer

D. M. Jones, Maintenance Engineering Technician

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L. Parr, Maintenance Engineer

K. Stenburg, Maintenance Engineer

T. Justis, Maintenance Engineer

H. Haby, Instrumentation & Controls Staff Engineer

W. Jones

Instrumentation & Controls Staff Engineer

B. Taylor, Instrumentation & Controls Engineer

R. D. Delano, Chemistry & Environmental Engineer

G. B. Moore, Chemistry & Environmental Supervisor

R. L. Thcimer, Chemistry Supervisor

• Denotes applicant representatives present during exit interview of

paragraph B.

The NRC inspectors also interviewed other applicant errployees during this

insoection period.

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2.

Applicant Actions on Previous inspection Findi_ng

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(Closed) Open Item 445/8436-05:

Applicant to provide a response

manual for the loose parts monitoring system.

In Sectinn 5.4.3 uf

'the Safety Evaluation Report (July 1981), the staff indicated

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acceptance of the applicant's loose parts monitoring system, The

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SRRI issued Open_ Item 445/8435-05 to track the applicant's issuance

of a response manual for the loose parts monitoring system.

On

October 10,1985, EDA-310,' " Analysis of Loose Parts Honitoring System

Data" was issued, which provides instruct,fons for, use of the syr; tem.

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This item (s closed.

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(Closed) Open Item 445/8502-01: Voiding of si0 natures in

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peopesational test data packages.

During roptine inspectiores of

ccmpleted preoperational test data patkages, the RRI noted

inconsistencies in the methods used by System Test Engineers (STEs)

to void cr supersede previous signatures when test steps had to be

repeated.

Section 4.8 of CP-SAP-21 required the STEs to void entries

by ifning through and signing (or initia11ing) the line-outs and

datin0 them.

Sometimes the STE failed to si n and date the line-out,

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thereby casting doubt on the part of a reviewer as to whether the

signature was for the line-out or for roperformance of the step.

The

RBI suggested that a more straight-forward method of superseding such

steps be considered.

The applicant has since responded that the

requirements of CP-5AP-21 will not be changed; thus the STCs will be

expected to comoly with Section 4.8 when voiding signatures.

This

$ tem is closed,

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(Closed) Open Item 445/8502-02:

Unclear justifications for test

precedure deviations (changes),

Whila reviewing completed

preoperational test data packages, the RRI identified a number of

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cases wlere the STE did not enter a cicar and concise reason or

justification for making minor chanpes to test procedures, which are

called test procedure deviations (TPDs).

It appeared that if more

cpe:ific directicn was orovided in Startup Administrative Procedure

C?-SAP-12, "Doviations to Test Instructions /Pracedures," this problem

might not have existed. The applicant has since issueJ Revi:f on 3 of

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CP-SAP-l> which directs the TF0 author to enter a detailed

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justification for each change.

The PRI reviewed the revised

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procedure and is satisfied with the change.

This item is clnsed.

d.

(Closed) Open Iten 445/3502-03: Post completion thanges to test

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docamentation. During an incpection of completed preoperational test

data packages, the RR1 identified wbst appesNd to be. post-completion

changes to test procedures using test dcficiency reports (TOHs) as

the authorizing dccument.

Althouah t.his practice did not nave any

adverse el'fects on the test records, administrative procedures did

not provide for such changes.

The applicant's response to this item

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was that test data packages were not being " revised or. changed" by

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TDRs, per se, but rather were being " annotated" to sh u the correct

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information found during the data pacta 3e review which was in t, urn

documented and evaluated by the TDR. This concern is being addressed

by recent changes to the Startup Administrative Procedures Manual to

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clarify the entry of corrections during completed test data reviews.

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. For example, on July 8,19M, Revision 6 to CP-SAP-11, " Review,

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Approval, and Retention of Test Results," was issued. The revised

administrative procedure now requires the Joint Test Group (JTG) to

document test data review comments and resolutions, and to include

this with the supporting documentation in the completed test data

package.

This will provide a means by which probleas fcund during

the JTG review of test data can be documented along with the

JTG-approved disposition.

The TDR will still be utilized to document

bonaffde deficiencies and corrective actions (including retesting, if

.sny); however, the applicant has indicated that changes or revisions

will not be made against completed test procedures.

This item is

closed.

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(Closed) Unresolved Item 445/8502-08:

Discontinuity between

reference drawing revisions in similar test procedures.

While

conducting an inspection of the completed preoperational test data

package for ICP-PT-29-03, Retest (RT)-2, the NRC Inspector noted that

the list of reference drawings containGd later revisions of the sar.e

drawings referred to in ICP-PT-29-03, RT-1, which was conducted later

than ftT-2.

The issue was whether or not failure to update the

references for 1CP-PT-29-02, RT-1 had any affect on test performance.

After the question was raised, the applicant responded by explaining

that Rf-1 did not have the correct revision numbers; however, since

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the objective of both tests was to start and load test the emergency

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diesel generators, the revisions of the reference drawings had no

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significace and thus did not affect the outcome nor the objectives

of the test.

The applicant filed a copy of the response and

explanation as a supplement to the completed test data packages for

ICP-PT-29-03, RT-1 and RT-2 for future reference.

This item is

closed,

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(Closed) Open Item 445/8502-11:

During an inspection of the

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completed preoperational test data package for ICP-PT-57-10, " Load

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, Group Assignment," the SRRI noted that TDR-3676 had ider.tified a

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failure to accomplish the slow transfer of train B bus 1EA2 when

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initiated by the test procedure.

Under corractive action, the TDR

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referenced Maintenance Action Request (MAR) 84-4036 to repair and/or

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adjust the auxiliary switches and actuating bar at a later date.

Meanwhile, per the TDR, the switches were placed in the required

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position manually so that the test could be resumed, including a

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repeat of the slow transfer test, which was successful. The MAR and

MAR retest documents were not in the test data package.

Subsequent

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RRI review of the completed MAR revealed that the actuatin0 bar was

in need of lubrication and operated freely once lubric6ted.

The

applicant's representatives explained that the state of the auxiliary

switches was in a condition required for accorplishneut of the test

and that testing of this breaker was not an objective of the test;

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thus, it 'was not necessary to repeat the applicable section of

ICP-PT-57-10 after the actuating bar was lubricated and successfully

exercised. This item is closed,

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.(Closed) Open Item 445/8502-12:

Potential impact of reference

drawing changes in preoperational test ICP-PT-57-10,

During the

completed test data package review of ICP-PT-57-10 conducted by the

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appifcant, TOR-3966 wasiissued identifying a failure to update the

correct revision of 15 drawings referenced in the test proceduro.

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The SRRI was concerned that r.o documentation existed in the completed

test data package showing that on evaluation was clade to determine

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the impact this might have on the test results.

The RRI verified

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that the applicant had'since conducted the evaluation, documented the

results on letter TSU-85169 of October 14, 1965, and incorporated the

letter into the completed test data package.

The evaluation did not

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identify any impact on test results.

This item is closed.

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(Cluted) Open Item 445/6506-02: Open TOR in a completed

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preos.erational te:t package.

During routine inspection of the

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completed preoperaticral te,t data package for ICP-Pf-64-01, the RRI

found TOR 3799 filed in the package with no evidence that it had been

properly dispositioned and closed.

Subsequently, the applicant's

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representative responded by explafning trat this TOR was not written

agiinst ICP-PT-64-01; however, it was filed in the package for

information only.

Any testing issues associated with this TOR and

the referenced containcent spray volves have been deferred to the

initial startup test pro!, ram.

The RRI fcund this to be adequately

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tracked by TUGC0 Operations under OPIR-85-002.

This item is closed.

3.

Maintenoce Procedg ej

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The objective of this inspection was to confirm that plant maintenance

procedures were prepared to adequately control maintenance and

surveillance testing of safety-relatea systems within applicable

regulatory requirements.

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The inspection included verification that:

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Adequate procedures and processes were in place for control of

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measuring and test equipment (M&TE);

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Procedures had been published for performing preventive and selected

corrective raaintenance;

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Adequate procedures and orograms existed for the implementation of

surveillances required by Technical Specificaticos (T5s);'

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All procedures were in the appropriate format as specified in the

administrative control manual, and that they were technically

adeqpate to acconplish their stated purpose; an+J

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Where appropriate, procedures prescrjbed steps in.portant tn the

protection of the health and safety of the workers and of the public.

The maintenance procedure inspection commenced in Septwbsr 1985 and

continued through completion in October 1985.

Details of the inspection

condu,:ted in September 1995 were reported in Appendix 0 of NRC Inspection

' Report No. 50-445/85-13.

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Ti'e following procedures were reviewed by the NRC anspector ablch met.

the cbjectives of this inspection and for which there were r.o

coments .or adverse findin0s:

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INC-101, Revision 4, "I&C Maintenance Program";

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INC-109, Revision 1, I&C Preventive Maintenance. Pro 0 ram";

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INC-7323A, Revision 1, " Analog Channel Operational Test and

Channel Calibration - Steam Generator NR Level, Loop 1,'

Proter. tion Set III, CH 0518";

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INC-601, Revision 2, " Digital Multimeter Calibration";

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INC-624, Revision 2. " Pressure Test Gauge Calibration";

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INC-C31 Revision 1, " Dial-Type Ther.mometer Calibration";

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MMI-302, Revision C, " Reactor Coolant Pump Seal Replace.nent";

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>t11-320, Revision 0, " Pressurizer Spray Nozzle Inspection;

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EMI-313, Revision 1, dCentrifugal Charging Pump Motor

Inspection"; and

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EMI-806, Pevision 0, " Electric Penetration Removal, Repair, and

Installation."

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Procedures INC-2006X, Revision 0, " Filling and Venting Flow .,nd

Dif forential Pressure Transmitters (Water or Steam)," and INC-2007X,

Revision 0, " Venting and Filling Pressurizer and Steam Generator

level Transmitters," were found to not tocot the objectives of this

inspection as identified below.

On March 21, 1985, Severity Level IV

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Notice of Violation 445/8445-02 was issued citing the applicant for

failure to provido adequate procedures appropriate to circumstances.

The circumstances involved an Inst. ruer.entation .and Control (I&C)

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technician who attempted to fill a pressurizer level detector

reference leg while the plant was hot in accordance with an

inadequate procedure (i.e., 101-2007), which led to errors and a

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first degree tnormal born on his forearin. One of the preventive

l actions in tho applicant's response to the violation dated

April 15, 1985, was to re/ise 101-2007 which became INC-2007X.

Another action was to review the remaining applicable procedures for

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. similar procedural problems.

The applicant stated that there were no

other procodyral problems that would result in a, similar incident.

101-2006 was amarg those reviewed and it has since become INC-2006L

In light of the problems found by the RRI when he reviewed these two

representat.ive procedures, violation 445/8445-02 could not be closed.

This was discussed with applicant managemerit during the exit

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interview of November 1, 1985, and acknowledged.

The revised precedures (INC-2006X and INC-2007X) contained steps that

were unnecessary, and contained instructions to perform prepa-ations

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e., asser511ng test egulpent) in a radiation area when they

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could have been dore in a nonradiation area.

It was apparent to the

NRC int 00ctor that MARA progr.am considerations were not incorporated

into the procedares. The ALARA ("As Low As Reasonably Achievable")

P.*ogreu is frplemented by HAA-101, "ALARA PROGRAM," which requires

procedurea, planning, and trairdng to ensure all ionizing radiation

exposure 11 reductd to as icw as reasonaoly achievable on the basis

of the state of techno1cgy and tha ecconet ts of reducing exposure

relative to the benefits realized.

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Both of the above praccdures were inconsistent as to how to f r.olate

and equalize differential pressure detectors.

Some steps were not flagged for radiological controls when

potentially radioactive material was to be handled.

Double valve isolation was not utilized as required by INC-101 to

protect the I&C technicians from temperatures in excess of 200 F.

Filling and venting of differential pressure detectors should include

sweeping air bubbles out through the equalizer valves.

INC-2006X did

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not provide for this.

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INC-2007X had a caution pote which stated that the reference legs are

connected to the high pressure side of the sensors.

Tt.is is not true

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in the case of Rosemount Detector ILT-459F, thus the procedure does

not accurately reflect the equipment to which it is to be applied,

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indicating inadequate procedure reviews.

The above deficiencies were discussed in detail with the cpplicant's

representative, who subsequently provided the NRC inspector with a

sample mark-up of INC-2007X which reflected acknowledgement and

correction of the deficiencies discussed.

Sin'ce correction of

deficiencies such as the above is related to corrective actions

associated with violation 445/8445-02, additional tracking of this

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issue is not necessary.

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There were no additional violations or deviations identified.

4.

Preventive Maintenance Programs

-The RRI is conducting an on going inspection to verify that an adequate

preventive maintenance program is scheduled and implemented, both from a

routine equipment readiness standpoint, and in consideration of the length

of shutdown time between Unit 1 preoperational testing and startup.

This

inspection includes verification that adequate controls exist to ensure

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equipment maintenance will be followed by appropriate tracking and

. performance of retests prior to restoring the equipment to an operational

status.

The NRC inspector interviewed applicant representatives responsible for

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the implementation and tracking of preventive maintenance and surveillance

testing.

Three groups have separate responsibilities in this area:

o Maintenance Engineering:

Mechanical and electrical maintenance,

including meter and relay maintenance.

o Instrumentation & Control:

Maintenance of plant system

instrumentation and controls.

o desults Engineering:

Surveillance tests and inspections

required by TSs.

. Maintenance Engineering has implemented a plant equipment preventive

maintenance program in accordance with Maintenance Department

Administration Procedure MDA-301, ". Preventive Maintenance Program." The

program was developed to satisfy the' requirements of ANSI N18.7-1976 as

well as the maintenance manuals furnished by Westinghouse and other

vendors. The scope of the program encompasses all electrical and

mechanical equipment that are not assigned specifically to the I&C group.

I&C implements an overall maintenance program on equipment within their

cognizance in accordance with INC-101.

There are other subordinate

implementing procedures, such as INC-107, which cover all scheduled

calibrations and all required TS surveillance items that are assi ned to

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I&C.

INC-109, for example, covers all preventive maintenance not already

covered by INC-107.

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- Results Engineering will implement:the surveillance program in accordance

with STA-702, " Surveillance Test Program." This provides for scheduling,

tracking, review and disposition of the records for all surveillances

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required by the TSs.

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The RRI interviewed representatives from each of the above groups, at

which time the respective programs were explained. In general, it appears

that' a comprehensive preventive maintenance program is in place, that is

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managed through computer scheduling and tracking programs.

During future

NRC inspections,"it will be determined if the programs are effective and

- the equipment is being maintained in a satisfactory state of readiness.

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The RRI reviewed chemistry records' for steam generators and primary fresh

water cooling systems between January 1983 and September 1985 to ensure

that required records were in place, that corrective measures were

promptly'taken when out-of-specification results were obtained,'and that

there was a full continuity of samples taken consistent with frequency

requirements.

This review identified the concerns discussed below.

The primary fresh water cooling systems chemistry results were recorded on

Form CHM-508-1, which is required by CHM-508, " Chemistry Control of the

. Primary Cooling Systems." Systems under the purview of this procedure are

Safety Chill Water, Non-Safety Chill Water, Diesel Generator Water

Jackets, Component Cooling Water, and BTRS Chill Water.

In general, a

lack of data entry discipline existed, but with an improving trend, from

January 1983 to present.

For example, in many cases sample results were

not entered, but there was no explanation.

Presumably, the systems were

drained or otherwise not available for sampling.

Out of-specification

conditions.were not flagged such that the RRI could determine that

necessary notifications and corrective actions were implemented.

Specifically, weekly samples were taken 10 to 12 days apart in

November 1983. Sample data entries did not exist in the Records Center for

the weeks of March 28, 1983; June 7,.1983;~ June 14, 1983; June 21, 1983;

, June 28, 1983; October 3, 1983; December 16, 1983; December 23, 1983; and

December 30,'1983.

Steam generator chemistry results for No. 1 and No. 2 steam generators

were reviewed for the period between January 1984 and September 1985.

The

data appeared on Form CHM-501-1 which is a requirement of CHM-502,

" Chemistry Control of the Steam Generators."

In many cases,

out-of-specification results were not flagged as required by CHM-501,to

indicate that the shift supervisor was notified and at what time.

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samples were not taken, but no explanation existed.

As was the case with

primary cooling systems, the attention te detail expected to be seen on

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such records did not appear to exist, even though all the forms were.

-reviewed and approved by supervision.

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Specifically, pH for both steam generators was recorded as being

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out-of-specification low (i.e. , as low as 9.0 when a range of 9.8 to 10.5

was required by CHM-501, Attachment 1) from June 20, 1984,through

October 8, 1984,'with no apparent explanation. When the RRI questioned

this, the applicant's representative explained that there had been a

considerable amount of discussion between the applicant and Westinghouse

and that there had been no urgent need to correct the condition since the

steam generators were in cold wet layup.

At the time, the applicant could

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not produce documentation supporting this information.

The RRI was

presented with a copy of Problem Report PR84-361 which was originated on

- October 5,1984; over three months after the problent of low pH became

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known. The report did not identify the pH as having been

out-of-specification low for over three months, but, rather, stated that

the mechanical seals on the recently installed recirculation pumps were

leaking, causing carbon dioxide entrainment, which in turn caused a

" depression" of pH in the steam generators.

The engineering review did

not evaluate the effects of the long-term pH depression on steam

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generators. The RRI was also presented with Independent Safety

Engineering Group Report 84-03, which documented a review of steam

generator water chemistry control.

The review included the period when pH

was depressed, but stated that, ". . . Plant chemistry personnel report

that the steam generators chemistry sample data is stable and no problem

areas have been noted." There was no mention of the pH problem. The

report concluded, ". . . prompt response to out-of-specification

conditions indicate that no significant corrosion related damage has

occurred in the Unit 1 steam generators." The applicant was requested to

provide the RRI with documented evidence which proves that the quality of

the primary and secondary boundaries of the steam generators had not been

compromised as a result of over three months out-of-specification low pH.

This is an unresolved itera (445/8514-U-01).

The concerns identified above with respect to what appears to be missed

chemistry samples, failure to indicate when and if the Shift Supervisor

was notified as out-of specification results were obtained, a lack of

records to indicate corrective actions taken, and inadequate reviews of

data forms constitute a violation of Criterion XVII of Appendix B to

10 CFR Part 50 (445/8514-V-01).

5.

Plant Tours

During this reporting period, the SRRI and RRI conducted inspection tours

of Unit 1.

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

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(Workinprogresswasbeingaccomplishedusingapprovedprocedures;

o.

,

~

Special precautions- for protection of ' quipment were linplemented, and

o

e

.

additional cleanliness requirements were being adhered to for

'

maintenance,' flushing, and welding activities;>

s

,

-

,

Installed safety-related equipment'and components were being

'

o

,

protected and maintained to prevent damage and deterioration.

3

,

Also during~ these tours, the SRRI and RRI reviewed the control room and

"

shift supervisors', log books.

Key items in the log review were:

'

!.

o.

plant status,

-

,

o

changes'in plant status,

g

,

o

tests'in progress, and

o

documentation.of problems which arise during operating shifts.

'

No violations 'or deviations were identified.

.

~6 .'

Unresol'ved Items-

'

Unresolved items are matters for which more information is required in

order to ascertain whether they.'are acceptable items, violations, or

deviations. One unresolved item disclosed during the. inspection is

discussed in paragraph 4.

'-

7.

Plant' Status as of October 31, 1985

'

a.

Unit No. 1 is reported to be 99% complete; however, excavation is

underway to facilitate replacement of main condenser internals'and a

i

significant amount of rework' continues on the control room ceiling.

I

b.

Unit No. 2 is reported to be 77% complete.

The preoperational test

program on systems associated with hRC inspections has not yet

started. '

'

-

s

8.

Exit Interview

~

'

c

.

. .

.,

,

l

An exit interview was conducted November'1,~ 1985, with the aoplicant

'

representatives identified in paragraph l'of this appendix. -During this

F

interview, the NRC-inspectors summarized the scope and findings of the

j

inspection. .The applicant' acknowledged the findings.

'

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,

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4

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-

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