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Insp Repts 50-445/88-44 & 50-446/88-40 on 880608-0706. Violations Noted.Major Areas Inspected:Significant Deficiency Rept Followup,Preoperational Retesting Program, Plant Tours,Ser Followup & Allegation Review & Followup
	ML20151F267
Person / Time
Site:	Comanche Peak
Issue date:	07/22/1988
From:	Bitter S, Burris S, Joel Wiebe; NRC OFFICE OF SPECIAL PROJECTS
To:	;
Shared Package
ML20151F243	List: ML20151F241; ML20151F253; ML20151F267;
References
	50-445-88-44, 50-446-88-40, NUDOCS 8807270008
	Download: ML20151F267 (14)
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APPENDIX B

U. S. NUCLLAR REGULATORY COMMISSION

OFFICE OF SPECIAL-PROJECTS

, NRC Inspection Report: 50-445/88-44 Permits: CPPR-126

50-446/88-40 CPPR-127

Dockets: 50-445 Category: A2

50-446

Construction Permit

Expiration Date:

Unit.1: August 1, 1988

Unit 2: Extension request

submitted.

Applicant: TU Electric

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2

Inspection At: Comanche Peak Site, Glen Rose, Texas

Inspection Conducted: June 8 through July 6, 1988

Inspector: _ Tucy 22.; /f 69

S. D. Bitter, Resident Inspector, Date

Operations

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Inspector: /fgh

S. P. Burris, Senior Resident Inspector, C/ Dhte

Operations

Reviewed by:. / 8), / kh

O. S. Wiebe, Lead Project Inspector {/ qfte /

8807270008 880722

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- Inspection Summary

Inspection Conducted: June 8 through July 6, 1988'(Report'

50-445/88-44; 50-446/88-40)

Areas Inspected: Routine unannounced resident safety inspection of

applicant's action on previous inspection findings, significant

1 deficiency analysis report follow-up, preoperational retesting

program, plant tours, safety evaluation report follow-up, and

allegation review and follow-up.

Results: During the inspection, one violation and one open item

were identified in the area of identification and correction of

deficiencies (paragrcph 2.b). The violation which includes several

examples indicates a potential weakness in.the applicant's program.

One open item was identified during SDAR follow-up (paragraph 3) l

and another open item was identified during review of the

preoperational retest program (paragraph 4). The preoperational

retest program was strengthened by the applicant by placing it

under a single administrative control system (paragraph 2.a). .

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DETAILS

1. Sersons Contacted

R. P. Baker, Licensing Compliance Manager, TU Electric

J. L. Barker, Manager, Engineering Assurance, TU Electric

M. R. Blevins, Manager, Technical Support, TU Electric

J. T. Conly, APE-Licensitg, Stone and Webster Engineering

Corporation, (SWEC)

W. G. Counsil, Executive Vice President, TU Electric

G. G. Davis, Nuclear Operations Inspection Report Item

Coordinator, TU Electric

D. E. Devincy, Deputy Director, QA, TU Electric

W. G. Guldemond, Executive Assistant, TU Electric

P. E. Halstead. Manager, Quality Control (QC), TU Electric

T. L. Heatherly, Licensing Compliance Engineer,

TU Electric

R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

S. D. Karpyak, CPRT, TU Electric

J. J. Kelley, Manager, Plant Operations, TU Electric

O. W. Lowe, Director of Engineering, TU Electric

J. W. Muffett, Manager of Civil Engineering, TU Electric

D. M. Reynerson, Director of Construction, TU Electric

M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric

C. E. Scott, Manager, Startup, TU Electric

J. C. Smith, Plant Operations Staff, TU Electric

S. L. Stamm, Project Engineering Manager, SWEC "

P. B. Stevens, Manager, Electrical Engineering, TU Electric

C. L. Terry, Unit 1 Project Manager, TU Electric

J. R. Waters, Licensing Compliance Engineer, TU Electric

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C. E. Watters, QA Program Manager, SWEC

The NRC inspector also interviewed other applicant employees )

during this inspection period.

Denotes personnel present at the July 6, 1988, exit

interview.

2. Applicant's Action on Previous Inspection Findings (92701) i

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a. (Closed) Open Item (445/8717-0-01): Insufficient

specificity to determine which group has administrative

responsibility for the preoperational test program. This

item was identified during a review of draft procedures

for controlling retesting activities. It had remained

open pending the issuance of clearer guidelines as to

which systems, components, and structures are under a

particular department's administrative control.

During the inspection, the NRC inspectors determined that !

the applicant has now placed the Unit 1 preoperational

retest program (Prestart Test Program) under a single set

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of administrative controls. The inspectors verified that

the following procedures contain the specific language

needed te clearly define which systems, components, and

structures fall within a particular manager's control:

. Station Administration Procedure (STA) 808A,

Revision 1: Unit 1 Prestart Test Program. This

procedure applies to all Unit 1 and common systems

for which testing is required prior to power

opera. tion.

Section 5.3 assigns the responsibility fu.?

developing the Prestart Test Program to the

Manager, Startup and Test.

Section 5.4 assigns the responsibility for

l implementing the Prestart Test Program to the

l Unit 1 Test Manager.

Section 6.1 outlines the administrative

controls for impl aienting the Unit 1 Prestart

Test Program.

Section 6.2 explains that formulating the

testing matrices will be performed in STA-809A.

l . STA-809A, Revision 0: Development of System Test

l Matrices. This procedure applies to all Unit 1 and

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common systemu that are to be tested prior to fuel q

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Section 5.0 assigns the responsibility for j

approving the test matrices to the Manager, i

Startup and Test. lj

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Section 6.0 provides step-by-step instructions l

to develop test matrices. i

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. Test Department Administration Procedure (TDA) 101, l

l Revision 0: Test Department Organization and j

Responsibilities. This procedure applies to all >

Test Dcpartment personnel and to those p ersonnel j

responsible for providing support to the Test

Department.

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Sec; fen 5.1.8 assigns the responsibility for

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developing and implementing the Prestart Test

Program to the Manager, Startup and Test.

. STA-606, Revision 8: Work Requests and Work Orders.

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Section 2.0 stipu2ates that all startup testing

on components / systems in. operation's custody be

performed under an authorized work order.

Based on this review, the inspectors concluded that the

necessary administrative controls appear to be in place

to enable proper implementation of the Prestart Test

Progrem. Therefore, this item is closed,

b. (Closed) Unresolved Item'(445/8839-U-01): Identification

and resolution of deficient conditions. This item

resulted-from examples of the applicant's failure to

formally document deficient conditions.

The NRC requested-that the applicant provide any

additional information which would show that these items

had been formally identified and documented. The

applicant did not provide any undiscovered documentation,

hotiever, the applicant cammitted to prcporly identify

each of these conditions and provide root cause analysis,

imp 1.ementing the appropriate corrective action to prevent

reoccurrence.

. The inspectors noted that discrepancies (conditions

adverse to quality) between issued field drawings

associated with setpoints of various protective

relays and actual equipment configuration were not

formally documented by a deficiency report (DR) or '

nonconformance report (NCR) and, therefore, were not

promptly corrected. ,

. The inspectors noted that during the overhaul of the

steam driven auxiliary feedwater pump a condition

adverse to quality (wrong gasket) was not formally

documented by a DR or NCR and; therefore, the' root

cause was not promptly identified and corrected.

. The inspectors noted during a review of control room

logs that Temporary Modification 65-0573 did not '.

have the required tag attached. This "condition

adverse to quality" was not formally documented by a-

DR and, therefore, the root cause was not promptly

identified and corrected.

. Subsequent review of the QA surveillance issue

identified in NRC Inspection Report 50-445/88-39

paragraph 7.b determined that this item was not an

example of a violation. The inspectors noted that

since the QA surveillance program required that each

identified discrepancy be documented using the

appropriate QA discrepancy forms, it was not

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necessary for the applicant to generate a DR or NCR.'

However, the inspectors questioned the reason

certain activities did not appear to have been

formally documented as outlined in the identified

NRC inspection report above. The inspectors will

review this issue further in a future inspection

period. This will identified as an open

item 445/8844-0-03, "Documentaticn of QA

Discrepancies."

The first three items described above are examples of an

apparent violation of 10 CFR Part 50, Appendix B,

Criterion XVI, which requires, in part, that measures be

established to assure that conditions adverse to quality

are promptly identified and corrected (445/8844-V-01).

The CPSES Operations Administrative Control and Quality

Assurance Plan, Section 3.9, paragraph 2.0, specifies

that conditions adverse to quality shall be promptly

identified and dispositioned. Paragraph 3.0 specifies

that measures governing the control of nonconformances

and deficiencies shall be contained in the appropriate

procedures manuals as implementing procedures established

by the Nuclear Engineering and Operations Policies and

Procedures Manual.

The CPSES Station Administration Manual (the appropriate

procedures manual) Procedure STA-404, paragraph 6.1

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contains the instructions for use of DRs and

Procedure STA-405 contains the construction for use of

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NCRs.

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The unresolved item is closed and changed to a violation.

3. Significant Deficiency Analysis Report (SDAR) Follow-up I

(92701)

i a. (Closed) SDAR CP-83-09: Reactor trip switchgear. In

1983, the vendor (Westinghouse) for the reactor trip

l switchgear informed TU Electric that there existed the

potential for misoperation of the Model DS-416 reactor

trip switchgear undervoltage (UV) attachments. This

concern was based on reports received by the vendor that

indicated that one Model DS-416 reactor trip breaker at

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each of two plants had not tripped during preplanned

l testing of the UV trip function. Subsequently, the

vendor identified two factors which most likely caused

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these occurrences:

. Manufacturing variations allowed interfer'nce

between the moving core and the roller bracket on

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one of the UV devices. A lack of sufficient

side-to-sido clearance for the roller bracket may

have been a contributing factor.

. The lack of a minimum gap between the breaker trip

bar pin and the UV trip reset lever.

The vendor determined that replacing the UV and shunt

trip coil assemblics and adding an auto shunt trip panel

to the DS-416 reactor trip switchgear would prevent

further occurrences. The NRC inspectors confirmed that

these modifications have been made to the

TU Electric DS-416 reactor trip switchgear. Furthermore,

the inspectors reviewed the following field change

notices (FCNs) associated with the modifications as well

as the operation's travelers and sign-off sheets

associated with each FCN:

TCXM-10588

TCXM-10589

TCXM-10592

TCXM-10615

TCXM-10621

TCXM-10626

TCXM-10627

No discrepancies were noted; therefore, this item is

closed,

b. (Closed) SDAR-CP-86-29: Acceptance testing of

air-operated valves. This issue arose when the original

architect-engineer, Gibbs and Hill, expressed concern

that the acceptance test procedure for the instrument air

system did not properly consider the requirements of

Regulatory Guide 1.80 concerning the testing of

air-operated valves. It is the applicant's position that

the use of Regulatory Guide 1.80 is limited to

safety-related systems and that, per FSAR, Section 9.3.1,

the instrument air system is not nuclear safety-related;

therefore, the testing of the instrument air system is

not bound by Regulatory Guide 1.80 requirements. The NRC

inspectors reviewed this issue and determined that it is

not reportable under the provisions of 10 CFR 50.55(e).

Therefore, this SDAR is closed. However, because there

is generic NRC concern about the testing of instrument

air systems and air-operated valves, the testing of the

instrument air system will be tracked as an open item

pending NRC review of the applicant's testing of the

instrument air system (445/8844-G-01).

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4. Preoperational Retesting Program (70301 & 70302)

The inspectors reviewed the current status of prerequisite

testing, procedure completion, system flushes, and

preoperational retesting. During this review, the applicant

presented documentation detailing the status of developing the

143 test procedures that are required. Of the 143 procedures,

63 have been issued for comment, 2 issued for approval, and 1

has been approved.

No discrepancies were noted in reviewing the areas listed

above. However, during one of several preoperational status

tours in the plant, the inspectors questioned the cause of a

water spill that had occurred during a flush of the component

cooling water (CCW) system. Upon questioning, startup

personnel stated that an initial review of the incident

indicated that the root cause was personnel failing to

properly verify the valve lineup prior to flush initiation.

This incident and other CCW activities will be the subject of

follow-up during the next reporting period (445/8844-0-02).

No violations or deviations were identified.

5. Plant Tours (71302)

The NRC inspectors conducted plant tours during this

inspection period. These tours provided coverage during

normal, off-normal, and backshift working hours. During the

tours, inspection activities included reviewing work

documentation, witnessing ongoing work activities, observing

and interviewing shift operations personnel, reviewing the

status of control room construction work, reviewing the status

of system and component completion, observing the status of

Units 1 and 2 equipment lay up, observing housekeeping

activities, and inspecting for general safety compliance.

To support these activities, NRC inspectors attended

plan-of-the-day meetings and observed shift turnover

briefings.

During the course of the tours and inspections, the NRC

inspectors noted the following:

(1) Housekeeping activities are being adequately

implemented.

(2) The Unit 2 lay up program is in progress.

Fifty-nine of the 78 major systems are currently in

lay up; most of the remainder are scheduled to be

placed in lay up by the end of July.

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(3) Discussions with control room personnel indicated l

that they are cognizant of the maintenance, lay up, '

and flush status of systems in Units 1 and 2.

No violations or deviations were identified. l

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6. Safety Evaluation Report (SER) Review and Follow-up (92719) I

Comanche Peak SER (NUPEG 0797) includes various commitments l

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and requirements that the applicant must meet prior to the

NRC's decision on issuance of an operating license. The

following items, listed by section number in the SER, were

reviewed by the inspector.

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Section 6.3.4.1. The applicant committed to developing a ;

procedure for inspection of the containment and containment !

recirculation sump to prevent collection of debris and sump

blockage. The inspector verified that adequate requirements i

for such inspection: are contained in Operation Testing Manual l

(OPT) Procedure 305, Revision 1, "Containment Close Out

Inspection." Specifically, this procedure states that the

applicant will visually inspect all areas on all levels of

containment for any loose debris (rags, trash, clothing, i

packing material) each time prior to establishing containment l

integrity. l

Section 8.2.4. The applicant committed to having plant

operating procedures require that degraded voltage conditions l

be corrected within approximately one hour to prevent '

long-term degradation of Class lE equipment. The inspector

verified that Abnormal Operating Procedure 601A, Revision 2,

requires that if the 6.9kv and 480V bus voltages cannot be

restored to their limits (6210-7260 volts and 440-500 volts,

respectively) within one hour, then the safeguard buses should

be transferred to the alternato power supply per Standard

Operating Procedure (SOP) 603, "6900 Volt Switchgear." If

this does not restore the voltage to within limits, then

SOP-609A, "Diesel Generator System" calls for using the diesel

generators to power the safeguards buses.

7. Allegation Review and Follow-up (99014)

(Closed) Allegation (OSP-87-A-0105): During the past several

inspection periods, the inspectors reviewed the applicant's

historical documentation concerning the purchasing, storage,

and installation of flow elements (orifice plates) at the

Comanche Peak site. This review was initiated due to concerns

expressed by a former employee who felt that certain

improprieties were involved in the purchase and use of various

flow elements.

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Two NRC inspectors met with the alleger and determined that

the former employee had four areas of concern:

. Numerous flow elements alleged to have been ordered even

though they were known to be of improper size.

. At.least several flow elements with the same

identification number were alleged to be maintained on

site even though these flow elements were not

manufactured to the same specification; 1.e., a

particular 12 inch orifice plate with a 1 inch flow

orifice hole and a 12 inch orifico plate with a

11.75 inch flow orifice hole were alleged to have the

same idc;.tification number.

. Specifications for flow elements were alleged not to have

been revised to reflect the correct orifice requirement.

. The alleger stated that these problems were identified to

management in 1980 via a memorandum and meeting; however,

the alleger was transferred and subsequently fired.

Furthermore, the allegcr contends that he was the subject

of discrimination on several occasions.

The inspectors reviewed the applicant's records concerning the

purchase of flow elements. These records included Gibbs and

Hill Specification 2323-MS-0624; Westinghouse Purchase order

546-C16-254678-BN; Westinghouse Field Change Notice

546-CLM254678-BN; Gibbs and Hill Specification 2323-MS-624,

Shoots 01-06 through 01-30; Design Change Authorization

(DCA) 16366; TU Procedures ECE 5.03, ECE 2.13-07, STA-403,

STA-606, Preventive Maintenance Program MDA-301, MODS Input

Data Review MEI-007, Preventive Maintenance Implementation

MODS MEI-017, MODS Equipment History Data Input APP-361,

Maintenance Management Computer Program (MMCP); and the latest

Comanche Peak Q-list. The inspectors also reviewed 10

separate document control records (Nos. 45922.3185-001,

4591;.3182-196, 46052.3187-173, 47503.3241-115,

47863.3254-200, 48766.3291-063, 49105.3303-105,

49114.3304-137, 49968.3337-155, and 50439.3360-110) all

dealing with specification 2323-MS-0624. )

From this review the inspectors could not verify that:

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. Any flow elements of improper size were intentionally '

ordered.

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. Any orifice plates with different specifications were i

stocked onsite with the same identification number. l

. Any memoranda exists that substantiates the alleger's

concerns with flow c3ements.

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However, the inspectors did identify a problem in that

specifications for flow elements were not correct in all

onsite documentation. This item has been documented in NRC

Inspection Report 50-445/88-22; 50-446/88-19 as unresolved

item 445/8822-U-05. The inspectors are following up on this

item and will report on its status in future inspection

reports.

During the course of this review, the inspectors performed

walkdowns of various systems examining specific flow orifices

to verify that the installed equipment matched the applicant's

documentation. The documentation concerning the following

flow orifices was verified correct with exceptions noted:

. 1-FE-0925; the bore diameter was not reflected on all

as-built documentation. This problem was noted in NRC

Inspection Report 50-445/88-22; 50-446/88-19.

. 1FE-0928 Same as 1FE-0925.

The inspectors could not substantiate any of the specific

concerns expressed by the alleger. Based on the inspections

documented above and in NRC inspection Report 50-445/88-22;

50-446/88-19, this allegation is closed.

8. Open Items

open items are matters which have been discussed with the

applicant, which will be reviewed further by the inspector,

and which involve some action on the part of the NRC or the

applicant or both. Three open items identified during the

inspection are disevesed in paragraphs 2.b, 3.b, and 4.

9. Exit Meeting (30703)

An exit meeting was conducted on July 6, 1988; the applicant's

representatives present at the meeting are identified in

paragraph 1 of this report. No written material was provided

to the applicant by the inspectors during this reporting

period. The applicant did not identify as proprietary any of

the materials provided to or reviewed by the inspectors during

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this inspection. During this meeting, the NRC inspectors

summarized the scope and findings of the inspection.

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Maragerent levolve'ent in Allyring Quality.

2. I

3. Approach to Resolution of Technical lisves from a $afety Sund;; int.

Respohtive'est to NRC Initiative $. !

4. [n f orce*ent History.

5. Crerational and Constrwetton Events,

6. Sta f fing (including ranagement). i

SM11HG KEY: (for Categories 2 '

Cecitning and 3. provide nerrative basis fe,r

concluston)

Ca tegory 1

Category ? Category 2 - Decitning

Category )

/.

1

l[I Inspector (s) concerns adeo.'ately ai 4elled _or

~

l_l Inspection [ valuation fois being precetted.

Lear 1 Inspector e/hd4 7.pd-f 7 Section Chief /h, fd

SIGNATURE DATE

BAT

SIG:lATURE

UI-UNRESOLVED ITEM

01-0 PEN ITEM

NR-NOT RATED

ML20151F267

Text

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