ML20154R017
| ML20154R017 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/27/1988 |
| From: | Bitter S, Burris S, Joel Wiebe NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20154Q985 | List: |
| References | |
| 50-445-88-54, 50-446-88-50, NUDOCS 8810040128 | |
| Download: ML20154R017 (13) | |
See also: IR 05000445/1988054
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
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NRC Inspection Report:
50-445/88-54'
Permits: CPPR-126
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50-446/88-50
CPPR-127
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Dockets: 50-445
Category: A2
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50-446
. Construction Permit
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Expiration Dates
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Unit 1: Extension request
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submitted.
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Unit 2: Extension request
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submitted.
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Applicant:
TU Electric
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Skyway Tower
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400 North Olive Street
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Lock Box 81
Dallas, Texas
75201
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Facility Nam't
Comanche Peak Steam Electric Station (CPSES),
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Units 1 and 2
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Inspection Att
Comanche Peak Site, Gle.n Rose, Texas
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Inspection conducted:
August 3 through September 8, 1988
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9/2
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Inspector
S. D. Bitter, Resident Inspector,
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Operations
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Inspector
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S. P. Burris, Senior Resident Inspector,
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Operations
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Reviewed b :
J. S. Wiebe, Lead Project Inr.,ptsctor
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8910040108 880927
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ADOCK 05000445
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Inspection Summary
Inspection Conducted:
August 3 through September 8,
1988 (Report
50-445/88-54; 50-446/88-50)
Arcas Inspected:
Unannounced resident safety inspection of
applicant's action on previous inspection findings, follow-up on
violations and deviations, preoperational rotesting program, plant
tours, and safety evaluation report follow-up.
Results: During the inspection, one violation was identified in the
area of radiological controls (paragraph 5.b).
The violt. tion,
which includes two instances where an individual did not obtain the
appropriato administrative controls prior to entering a radiation
control area, indicaten a potential weakness in the applicant'r
program.
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DETAILS
1.
Persons Contacted
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- R. W. Acklcy, Jr., Project Manager, Stone & Webster
Engincoring Corporation (SWEC)
- M.
Axelrad, Attorney, Newman and Holtzinger,
P. C.
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- R.
P. Baker, Licensing Compliance Manager, TU Electric
- J.
L. Barker, Manager, Engineering Assurance, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- W.
J. Cahill, Consultant, TU Electric
- J. T. Conly, APE-Licensing, SWEC
- W.
G. Counsil, Executive Vice President, TU Electric
- J.
C. Crnich, Project General Manager, Ebasco
- G.
G. Davis, Nuclear Operations Inspection Report Item
Coordinator, TU Electric
- S.
H. Freid, Chief Mechanical / Nuclear Engineer, Bechtel
- P.
E. Halstead, Manager, Que.lity Control (QC), TU Electric
- T.
L. Hoatherly, Licensing Complianco Engineer,
TU Electric
- C.
B. Hog, Engineering hanager, Bechtel
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- R.
T. Jenkins, Manager, Mechanical Engineering, TU Electric
- J.
J. Kelley, Manager, I'lant Operations, TU Electric
- J.
E. Krechting, Director of Technical Interface, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- F. W. Madden, Mechanical Engineering Manager, TU Electric
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- D.
M. McAfco, Manager, QA, TU Electric
- J.
C. Miller, CPRT, Tenera
- J. W. Muffett, Manager of Civil Engineering, TU Electric
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- L.
D. Nace, Vice President, Engineering & Construction,
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TU Electric
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- E.
Ottncy, Representative, CASE
- S.
S. Palmer, Project Manager, TU Electric
- J.
D. Redding, Executive Assistant, TU Electric
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- D. M. Reynorson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- E.
J. Schmidt, Radiation Protection Manager, TU Electric
- A.
B. Scott, Vice President, Nuclear Operations, TU Electric
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E. Scott, Manager, Startup, TU Electric
- S.
L. Stamm, Project Engineering Manager, SWEC
- P.
D. Stevens, Manager, Electrical Engineering, TU Electric
- J.
F. Streeter, Director, QA, TU Electric
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- C.
L. Terry, Unit 1 Project Manager, TU Electric
- T.
G.
Tyler, Director of Projects, TU Electric
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D. Walker, Manager of Nuclear Licensing, TU Electric
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- K.
C. Warapius, Project Director, Impell
- J.
R. Waters, Licensing Compliance Engineer, TU Electric
The NRC inspector also interviewed other applicant employees
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during this inspection period.
- Donotes personnel present at the September 8,
1988, exit
interview.
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2.
Follow-up Previous Inspection Findings (92701)
a.
(Closed) Open Item (445/8722-0-09):
Completion of
analysis of circuits related to safe shutdown.
The NRC
inspector that opened this item reviewed the associated
circuit analysis and the CPSES calculation (No. 152,
Revision 4) that resulted in the need for modifications.
The inspector has determined that the applicant has
issued the design change authorizations (DCAs) necessary
to impicment the modifications.
Revision 4 of calculation No. 152 appears to have
adequately addressed this open item.
On the basis of the
NRC review and the modifications initiated by the
applicant, Item 445/8722-0-09 is closed,
b.
(closed) Open Item (445/8822-0-01):
Nonconforming lock
washer.
This item originated during observation of
electrical maintenance activitics on the Unit 1, Train B
residual heat removal (RHR) pump motor.
The pump motor
lower bearing had just boon modified and while attempting
to install a nut and locking tab washer on the rotor of
the motor, electrical maintenance discovered that the
lock washer provided would not fit without being
machined.
Because no documentation concerning the
machining had boon provided to electrical maintenance,
the reinstallations of the RHR pump motor was deferred
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until the applicant could determine the circumstances
surrounding this nonconformance.
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subsequently, the applicant determined that the locking
tab washer was procured properly using the correct stock
numbers furthermore, the correct part was roccived and
issued.
Apparently, the vendor failed to provide
sufficient documentation to indicate that the washer
needed to be modified slightly to fit the rotor shaft.
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In order to document this nonconformance, the applicant
initiated nonconformance report (NCR) 88-05961.
The
disposition of this NCR was to machine the washer (por
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the instructions of Westinghouse Field Deficiency
Report TBXM-10339) and to incorporate the machining
instructions in Maintenance Prnceduro MSE-Cl-4312, "RHR
Pump Motor Rowork."
NRC inspectors have verified the completion of these
actions; the pump motor has been reinstalled
satiafactorily.
Overall review of this item resulted in
no discrepancies; therefore, this item is closed.
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c.
(Closed) Open Item (445/8852-o-03):
Applicant's actions
concerning postulated oil spill as described in
NUREG-0797, "Safety Evaluation Report (SER) for CPSES
Unit 1 and Unit
2."
This item was open pending roccipt
of additional informaticn from the applicant.
In the
SER, Section 2.2.2, the staff states that the applicant
has indicated that station personnel will patrol the area
west of the safe-shutdown impoundment once a day to check
for oil pipeline breaks.
The inspectors reviewed
Security Post Order for Post 213 dated February 29, 1988.
The order requires, in part, a random mobile patrol of
the oil scopage ponds to check for oil spills or seeps.
The times of these patrols are designated by the security
shift sergeant at least once a shift.
The inspectors,
therefore, determined that there is reasonable assurance
that patrols will be conducted at least once por day as
specified by the SER.
The SER also states that the applicant has analyzed
several pipeline breaks and will install three retaining
ponds betwoon the pipeline and safe shutdown impoundment.
The inspector reviewed the applicant's analyses of
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pipeline breaks, reviewed the design drawings of the
three retaining ponds, and inspected the retaining ponds.
The inspectors have determined that there is reasonable
assurance that the retaining ponds will prevent an oil
line break from spilling oil into the safe shutdown
impoundment (SSI).
The inspectors had no further
questions in this area.
This item is considered closed.
d.
(closed) open Item (445/8852-0-04):
Higher than design
ground water level.
This item was open pending receipt
of additional information concerning the ground water
field monitoritig program.
The inspectors reviewed
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specification CPES-S-1035, Revision 1, "Borcholes and
Installation of Piezometers," dated January 13, 1988;
"Groundwater Monitoring Piezometer Installation Report
(Final)," dated May 9, 1988; and "Groundwater Monitoring
Six Month Evaluation Report" (January-June 1988).
The
inspectors determined that there is reasonable assurance
that the Groundwater Monitoring Program will fulfill the
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commitment made in the Safety Evaluation Report (SER).
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The preliminary revision of tha Groundwater Monitoring
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Six Month Evaluation Report (January-June 1988) indicates
that there is no evidence of a continuous static
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groundwater table or piezometric surface within the Glen
Rose formation to the depth investigated.
However, the
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report also indicates that groundwater occurs in isolated
zones (perched water) at various levels from elevation
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734 up to the rock surface.
As a result, the original
design water level (elevation 775) is no longer
justifiable.
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The inspectors reviewed design basis document
(DBD-CS-091), Revision 1, "Foundation Material
Properties," dated December 31, 1987, and determined that
although the original design basis water level was at
elevation 775, the plant design was checke.d for an
assumed groundwater level at elevation 810 (plant grade).
At the service water structure, groundwater was assumed
at elevation 780, 5 feet above the normal safe shutdown
impoundment water level.
All seismic Category I
structures were found to be stable.
The inspector
determined that there is reasonable assurance that the
assumed groundwater level at grade (elevation 810) will
not be exceeded.
However, it is not clear to the
inspectors that the assumed groundwater level
(elevation 780) for the service water intake structure is
adequate.
The preliminary version of the Ground Water
Monitoring Six Month Evaluation Report (January - June
1988) indicates that the groundwater level near the
service water intake structure is relatively constant at
elevation 783.
In addition, the SER states that during a
probable maximum flood (PMF), the maximum stillwater
level reached in the safe shutdown impoundment is at
elevation 790.5.
Significant Deficiency Analysis Report (SDAR) CP-88-23
dated February 4,
1988, was issued concerning the same
subject matter.
Open Item 445/8852-0-04 is closed and
the concern over the design basis groundwater icvel at
the service water intake structure will be followed by
SDAR-CP-88-23.
c.
(Open) Open Item (445/8852-0-05):
program for monitoring
sediment buildup in the SSI.
This item was open pending
rece.pt of information relating to the applicant's
commitment to a program for monitoring sediment buildup
in the SSI.
The inspectors reviewed Procedure EGT-758,
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Revision 1, "Safe Shutdown Impoundment Dam Inspection,"
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dated January 22, 1988, and the draft Revision 2 to this
procedure.
The procedure requires annual testing for
sediment buildup in the intake channel and if the
sediment depth exceeds 1.5 feet, the procedure refers to
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Technical Specification 4.7.5 which requires the sediment
to be removed wi. thin 30 days.
The inspector determined
that there is reasonable assurance that excess sediment
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will be detected.
The procedure states that when
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sediment removal is necessary, procedures will be
developed and approved to remove sediment from the intake
channel.
The inspectors are concerned that if excess sediment is
identified while the plant is in operation and must be
removed within 30 days, adequate forethought and
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preparation may not be utilized to develop the procedure.
Disturbing sediment and debris in the intake channel has
the potential for clogging pump suctions or discharge
filters thereby causing a common made failure of all
service water trains for the two units.
The failure of
the service water system would not only cause a plant
transient, but would cause a failure of the safety
systems required to mitigate the transient.
An activity
with this potential should be carefully analyzed and
reviewed without a 30-day time limit.
The applicant is considering a procedure change to
identify the approach of the silt icvel to the 1.5-foot
limit.
This would allow the applicant time to determine
the optimum time to conduit the silt removal activities,
time to develop procedures, and time to let a contract to
conduct the silt removal operation prior to reaching the
1.5-foot limit.
This item remains open pending the
applicant's action to change the procedure and NRC's
review of the procedure,
f.
(closed) Open Item (445/8852-0-06):
Annual riprap
inspection of the SSI.
The inspectors reviewed applicant
Procedure EGT-758, "Safe Shutdown Impoundment Dam
Inspection," Revision 1, dated January 22, 1988, and
draft Revision 2 to this procedure and determined that
the procedure requires the dam slopes to be visually
inspected to ensure there are no erosion-formed gullies
or wave-formed notches or benches that reduce the
embankment cross section or expose less wave-resistant
materials.
The inspectors found the procedure to be
adequate and this item is considered closed.
c.
(Closed) Open Item (445/8852-0-07):
Annual inspection of
SSI dam in accordance with Regulatory Guide 1.127,
Revision 1.
The inspectors reviewed applicant's
Procedure EGT-758, "Safe Shutdown Impoundment Dam
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Inspection," Revision 1 dated January 22, 1988, and draft
Revision 2 to this procedurc and determined that annual
measurements of piezometric levels and annual surveys of
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the surface alignment monument locators are required.
In
addition, the inspectors reviewed several of the annual
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dam safety inspection reports and determined that they
have the applicable information required by Regulatory
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Guide 1.127, Revision 1.
This item is considered closed.
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3.
Follow-up on Violations / Deviations (92702)
a.
(Closed) Deviation (445/8716-D-01):
Retest requirements
for previously accepted systems.
This deviation dealt
with the applicant's Operations Administration Procedure
STA-623, "Post Work Testing," Revision 1 dated June 26,
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1987, not containing administrative controls to ensure
adequate retesting of systams or design features which
have been maintained or modified following preoperational
testing.
Since the completion of the original
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preoperational testing program, there has been an
extended amount of time has elapsed and the applicant has
committed to several measures to ensure that systems are
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adequately tested and maintained in an acceptable
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condition.
First, the applicant is currently
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implementing the Unit 1 preoperational retest program
which will retest Regulatory Guide 1.68 requirements
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unless acceptable justification is provided on an
individual test basis.
Secondly, Procedure STA-623,
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"Post Work Testing," has been revised to include
administrative controls which:
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Outlines in more detail the types of post-work tests
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to be conducted;
i.e.,
equipment test, surveillance
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test, design modification acceptance test,
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preoperational test, acceptance test, and system
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test,
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Identifies specific organizational responsibilities;
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i.e.,
responsible work organization, responsible
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test organization, post-work test report review,
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system test matrix review, etc.
Identifies amount of detail for specific job
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responsibilities; such as, start up manager, I&C
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manager, etc.
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Adds a post-work test list which is used as a cross
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reference between required surveillance procedures,
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technical specification requirement, and the
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specific component tag number.
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In addition to the above change, the applicant reviewed
and revised the following procedures to include
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clarification of the impact of Regulatory Guide 1.68
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(Revision 2, August 1978) for testing prior to the
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issuance of an operating license.
STA-623, "Post Work Testing," Section 6.4.1.3 was
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revised to provide for a sign-off block verifying
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review for port-test review.
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STA-606, Revision 8, "Work Requests and Work
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orders," Section 6.8.1 was changed to provide
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Startup review of work orders for impact on
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preoperational test program.
Section 2.0 ensures
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that testing performed by Startup or
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components / systems in the custody of operations
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shall be performed in accordance with an' authorized
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work order.
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STA-808A, Revision 1, "Unit 1 Prestart Test
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Program," Section 2.0, states that the program is
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applicable to all Unit 1 and common systems required
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for safe power operation of Unit 1.
Figure 7.2,
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Unit 1 Prestart Test Program Flow Chart, references
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STA-809A, Revision 0,
"Development of System Test
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Matrices," Section "5.3 assigns responsibility for
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implementing the Unit 1 Prestart Test Program to the
Unit 1 test managar.
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Based on these changes to the Operation /Preoperation Test
Program, the inspectors consider this item closed.
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4.
Preoperational Retest Program Activities (70301, 70302)
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NRC staff obtained and reviewed the most recent information
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regarding Unit 1 Preoperational Retest Program.
This review
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included discussions with preoperational supervision and
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personnel, procedure status review, projected schedule
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(overall and individual test performance) and status of
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preoperational test procedure review and acceptance.
The
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applicant's published preoperational test procedure list shows
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that there are 146 total procedures for Unit 1 review, with
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106 procedures issued for comment.
Of these 106 procedures, 7
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have been approved for use.
The inspectors have requested
copies of the approved procedures for review during a future
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inspection period.
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There were no violations or deviations identified in the areas
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inspected.
5.
Plant Tours (71302)
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The NRC inspectors conducted planc tours during this
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inspection period.
These tours provided coverage during
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nornial, off-normal, and backshif t working hours.
During the
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tours, inspection activities included reviewing work
documentation, witnessing ongoing work activities, observing
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and interviewing shift operations personnel, reviewing the
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status of control room construction work, reviewing the status
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of system and component completion, observing the status of
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Units 1 and 2 equipment lay up, observing housekeeping
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activities, and inspecting for general safety compliance.
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To support these activities, NRC inspectors attended
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plan-of-the-day meetings, discussed plant status with
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operations personnel, reviewed plant lay up logs, and
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performed a walkdown inspection of all major Unit 1 systems in
lay up.
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a.
During the course of the tours and inspections, the NRC
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inspectors noted the following:
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(1)
The Unit 1 lay up status walkdown covered the main
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turbine generator, the diesel generator, the primary
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.and secondary systems, and electrical penetrations.
During the walkdown, the on-shift auxiliary
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operators accompanied the inspector; the operators
demonstrated to the inspector's satisfaction that
they were knowledgeable as to valve and component
locations, methods of verifying valve positions, and
methods of verifying lay up status.
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ancies were noted in this inspection of lay up
status.
(2)
Housekeeping measures appear to be adequately
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implemented.
(3)
observations of the component cooling water system
flush procedure and discussions with control room
personnel indicated that they are cognizant of the
flush lineup and status of the component cooling
water system.
b.
The radiation protection manager informed the resident
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insrectors of two separate instances where radiological
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barrier violations had occurred on two separate
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occasions, August 14 and 15, 1988.
The incidents
resulted when a contract employee, working in the fuel
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building, twice crossed a barrier into a radiation
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controlled area (RCA) in order to gain access to the fuel
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building bridge crano lower platform,
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In the second instance, as the employee crossed onto the
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erane's lower platform (thus crossing the boundary of the
radiation controlled area), a radiation protection
technician stopped him and informed him that he had
crossed a radiation controlled area boundary without
proper authorization in the form of a radiatjon work
permit (RWP).
The employee explained that he had crossed
the barrier in a similar fashion on the previous day.
Furthermore, he explained that he belic'.ed that he had
received permission from the responsible envincering and
security departments prior to crossing the boundary to
reach the crane's lower platform.
He based this belief
on a discussion he had with the fuel building
coordinator.
In this discussion, the fuel building
coordinator told the employee that he could enter green
badge security areas (areas above the 860 foot level in
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the fuel building).
Because the fuel building
coordinator thought that the employee did not want access
to the crane's lower platform, the fuel building
coordinator did not perceive that the employee was
actually asking for permission to enter a radiation
controlled area.
The preliminary cause of this violation appears to be
that neither the contract employee nor the security
personnel recognized that the crane's lower platform was
in a radiation controlled area. Contributing causes
appear to be that security personnel were under the
impression that. blue badge security areas (areas where
nuclear fuel is being stored or handled) were equivalent
to radiation controlled areas, that the barrier signs
posted did not include instructions to notify radiation
protection prior to entry, and that the work package did
not identify any of the contract employee's work as being
in an radiation controlled area and therefore, the work
permit did not call for radiation protection
participation.
The radiation protection department responded to these
incidents by issuing radiological incident / problem report
(88-0002) and a deficiency report (DR) P88-04086
documenting the occurrences.
Corrective actions include
improving the postings and barricades on the 860 foot
level, changing the security post order to include a
radiation protection escort for all blue badge area
entries, instructing the security personnel that blue and
green badges are for security purposes only, and that
personnel should contact radiation protection prior to
entry into radiation controlled areas.
The above constitutes a violation of the applicant's
special nuclear material license, and is identified as a
violation (445/8854-V-01): Unauthorized Entry into
Radiological Controlled Area.
6.
Safety Evaluation Report (SER) Review and Follow-up (92719)
Comanche Peak SER (NUR.EG 0797) includes various commitments
and requirements that the applicant must meet prior to the
NRC's decision on issuance of an operating license.
The
following items were reviewed by the inspector.
Section 9.3.2.
The applicant committed to install provisions
to sample containment sump water.
The inspector has
ascertained that the applicant has the capability to sample
the containment recirculation sumps via the Train A residual
heat removal pump.
The sampling procedure is covered in
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Chemistry Procedure CHM-512A, "Operation of the Reactor
Coolant Post Accident Sampling System."
7.
Exit Meeting (30703)
An exit meeting was conducted on September 8, 1988, with the
applicant's representatives identified in paragraph 1 of this
report.
No written meterial 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 this inspection.
During this mocting, the NRC inspectors summarized the scope
and findings of the inspection.
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50-445/83-66 50-446/88-5 0
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DISTRIBUTION:
Docket Files'(50-445/446))
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NRC PDR~
LPDR
CPPD-LA
CPPD Reading (HQ)
OSP Reading
- Site Reading File
R. Warnick
- J. Wiebe
- H. Livermore
- MIS System, RIV
- RSTS Operator, RIV
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DRP, RIV
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RIV Docket File
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- L.
Shea, ARM /LFMB
J. Taylor
J.
Partlow
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C. Grimes
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P. McKee
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J. Lyons
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J. Wilson
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M. Malloy
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D. Terao
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J. Moore, OGC-WF
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J. Gilliland, RIV
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F. Miraglia
E. Jordan
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B. Grimes
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B. Hayes
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- w/766
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