ML20151F267
| 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: |
| References | |
| 50-445-88-44, 50-446-88-40, NUDOCS 8807270008 | |
| Download: ML20151F267 (14) | |
See also: IR 05000445/1988044
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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
8), / kh
Reviewed by:.
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S.
Wiebe, Lead Project Inspector
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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
deficiency analysis report follow-up, preoperational retesting
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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)
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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
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- 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
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during this inspection period.
- Denotes personnel present at the July 6, 1988, exit
interview.
2.
Applicant's Action on Previous Inspection Findings (92701)
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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,
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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
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implementing the Prestart Test Program to the
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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.
STA-809A, Revision 0:
Development of System Test
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Matrices.
This procedure applies to all Unit 1 and
common systemu that are to be tested prior to fuel
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Section 5.0 assigns the responsibility for
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approving the test matrices to the Manager,
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Startup and Test.
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Section 6.0 provides step-by-step instructions
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to develop test matrices.
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Test Department Administration Procedure (TDA) 101,
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Revision 0:
Test Department Organization and
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Responsibilities.
This procedure applies to all
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Test Dcpartment personnel and to those p ersonnel
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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
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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
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nonconformance report (NCR) and, therefore, were not
promptly corrected.
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The inspectors noted that during the overhaul of the
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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
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logs that Temporary Modification 65-0573 did not
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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
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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
contains the instructions for use of DRs and
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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
(92701)
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a.
(Closed) SDAR CP-83-09:
Reactor trip switchgear.
In
1983, the vendor (Westinghouse) for the reactor trip
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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
each of two plants had not tripped during preplanned
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testing of the UV trip function.
Subsequently, the
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vendor identified two factors which most likely caused
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these occurrences:
Manufacturing variations allowed interfer'nce
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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
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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
that they are cognizant of the maintenance, lay up,
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and flush status of systems in Units 1 and 2.
No violations or deviations were identified.
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6.
Safety Evaluation Report (SER) Review and Follow-up (92719)
Comanche Peak SER (NUPEG 0797) includes various commitments
and requirements that the applicant must meet prior to the
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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
for such inspection: are contained in Operation Testing Manual
(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,
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packing material) each time prior to establishing containment
integrity.
Section 8.2.4.
The applicant committed to having plant
operating procedures require that degraded voltage conditions
be corrected within approximately one hour to prevent
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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
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though they were known to be of improper size.
At.least several flow elements with the same
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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
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been revised to reflect the correct orifice requirement.
The alleger stated that these problems were identified to
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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.
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From this review the inspectors could not verify that:
Any flow elements of improper size were intentionally
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ordered.
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Any orifice plates with different specifications were
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stocked onsite with the same identification number.
Any memoranda exists that substantiates the alleger's
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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
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as-built documentation.
This problem was noted in NRC
Inspection Report 50-445/88-22; 50-446/88-19.
Same as 1FE-0925.
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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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RP 0$168
$ ALP FUNCfl0NAL ARtA A$$t$$M(NT AND PR(LlHINARY lh5P(Cf0A EVA_LUl
50-445
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Fa: 111ty: COMANCHE PEAX (TUE)
Inspection Report No.: _50-446
1
FORTICNAL AREA 5
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PREOPERATIONAL TEST PROGRAM
2.-
CRITitlA FOR DETDAIN]WG CATEGORY ILAT!hG
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Maragerent levolve'ent in Allyring Quality.
2.
Approach to Resolution of Technical lisves from a $afety Sund;; int.
I
Respohtive'est to NRC Initiative $.
3.
4.
[n f orce*ent History.
5.
Crerational and Constrwetton Events,
6.
Sta f fing (including ranagement).
SM11HG KEY:
(for Categories 2
Cecitning and 3. provide nerrative basis fe,r
'
concluston)
Ca tegory 1
Category ?
Category 2 - Decitning
Category )
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l[I Inspector (s) concerns adeo.'ately ai 4elled _or
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l_l Inspection [ valuation fois being precetted.
Lear 1 Inspector
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7.pd-f 7 Section Chief
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fd
SIGNATURE
DATE
SIG:lATURE
BAT
UI-UNRESOLVED ITEM
01-0 PEN ITEM
NR-NOT RATED