ML20212P783
| ML20212P783 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/26/1986 |
| From: | Barnes I, Kelley D, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212P745 | List: |
| References | |
| 50-445-86-01, 50-445-86-1, NUDOCS 8609030272 | |
| Download: ML20212P783 (14) | |
See also: IR 05000445/1986001
Text
{{#Wiki_filter:- - - - _ - - - - - - - - _ - - - - - - _ _ _ _ _ _ _ _ - . _ _ _ _ _ - - - - - - _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ .- . , - 4. : , s ,,- _ . , - . ! . s ..g - - l, ' APPENDIX C " I OPERATIONS INSPECTION REPORT ^ U.S. NUCLEAR REGULATORY COMMISSION ~ ~ . REGION IV . - , HRC. Inspection Report: '50-445/86-01 Permit: CPPR-126 Docket: 50-445 Category: A2 Applicant: Texas Utilities Electric Company (TUEC) Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted: November 1, 1985, through January 31, 1986 Inspectors: mi [[m O/2.e/PL D. L.~ Kelley,'Sdni3r~Residyht Reactor Dat'e ' Inspector (SRRI), Regiorf IV CPSES Group (paragraphs 1, 2, 3, 5, 7, 8, and 9) SH 8/2.6 /86 [ W. F. Smith, Resident Reactor Inspector (RRI) Date Region IV CPSES Group . (paragraphs 1, 2, 4, 5, 6, 7, 8, and 9) l 3 8uo M26 /86 -Approved: - I. Barnes, Chief, Region IV CPSES Group Date 8609030272 860829 PDR ADOCK 05000445 G PDR - - - - - . . _ - - _ _ _ _ _
-2- . Inspection Summary Inspection Conducted: November 1,1985, through January 31, 1986 , (Report 50-445/86-01) Areas Inspected: Routine, unannounced inspection of (1) application actions o'n- . previous inspection findings, (2) station administrative procedure, (3) miscellaneous independent, (4) preventive maintenance programs, (5) 'lant, ' p tours, and (6) plant status. Results: Within the six areas inspected, one deviation (failure to preoperationally test the auxiliary feedwater pumps as committed in the FSAR, paragraph 4.c) was identified. ! . 4 i l > I , f I i
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__ -3- DETAILS 1. Persons Contacted ' Applicant Personnel
- A. B. Scott, Vice President, Operations
- T. J. Beaudin, Shift Supervisor
- D. L. Walling, Maintenance Engineer
S. 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
E. Alarcon, Results Engineer
- R. R. Wistrand, Administrative Superintendent
- D. W. Braswell, Engineering Superintendent
- J. C. Smith, QA
- T. L. Gosdin, Support Services Superintendent
M. J. Riggs, Operations Support Engineer L. Parr, Maintenance Engineer K. Stenburg, Maintenance Engineer T. Justice, Maintenance Engineer
- D. M. McAfee, Manager, QA
J. Allen, Jr. , Operations Engineer
- Denotes applicant representatives present during. exit interview 0f s
paragraph 9. , , The NRC inspectors also interviewed other applicant employees during this inspection period. s 2. Applicant Action on Previous Inspection Findings . a. (Closed) Violation (445/8431-07): Storage of quality and nonquality material in an area identified as a "Q" material storage area. During an inspection of the applicant's maintenance facility, the NRC inspectors observed quality and nonquality material stored together in an area of the maintenance facility which was identified by signs as "Q Material" or "Q Material Storage Area." Applicant Procedure MDA-404, " Control of Material, Parts and Components," addresses control of material during maintenance. The applicant proposed to provide additional training to clarify and stress the control of storage of quality material while work is in progress. i This material control problem appeared to be confined to the maintenance building and also to have been an isolated case. As the SRRI conducted followups and other plant tours, other areas of I maintenance have not exhibited this problem nor has it been repeated l in the maintenance building. This item is closed. i ! - - - - - -- - , . _ - - . _ , , . - -
-4- b. (Closed) Violation (445/8431-14): Program inadequacies in measuring and test equipment (M&TE). During an inspection of the equipment M&TE program, several inadequacies were noted in Procedure STA-608, Revision 5, " Control of Measuring and Test Equipment." The inadequacies have since been eliminated by Revisions 6 and 7 of the procedure. This item is closed, c. (0 pen) Violation (445/8431-05 (a-f)): Failure to follow procedure. The violation cited six examples in this area. The applicant has since revised two procedures to clarify the requirement and conducted retraining on these and other procedures. However, this item remains open due to incomplete action in one area. Specifically, the response to Violation 445/8431-05(a) indicated that a number of maintenance " procedures," including the one in question (ELM-302, "480V Air Circuit Breaker Inspection"), have been downgraded from " procedures" to " instructions." CPSES Administrative Procedure MDA-201, " Electrical and Mechanical Maintenance Procedures and Instructions," appears to define the difference between " procedures" and " instructions" as to whether or not performance of actions in accordance with the document, when applicable to safety-related equipment, will affect plant operation. Since the level and extent of review, approval and change control for " instructions" appears to be less than that required by the administrative manuals for " procedures," it follows that the level of quality could potentially be diminished, which is unacceptable. The fact that a system, sub-system, or component may be isolated from the operating part of the plant for the purpose of facilitating the safe performance of work does not change the quality requirements. The downgrade from " procedures" to " instructions" implies a degradation of quality, which increases the probability of error. The. applicant has previously demonstrated a deficient performance in the review of procedures as referenced in Notice of Violation-items 445/8445-02 and an i' adequate procedure was 445/8506-02. In the case of 445/8506-02, n one cause of an improper change to an instruction, which ultimately resulted in a damaged reactor coolant pump seal and consequent. breach of cleanliness of the seal annulus. Thus, it appears that- - downgrading of the review requirements for documents wh'ich control' work on safety-related equipment is not justified. - As a result of the foregoing, the NRC inspector considers that this violation cannot be closed until the applicant takes appropriate actions to correct unacceptable differences between.the level of ' reviews for documents controlling work on safety-related equipment that may or may not be temporarily isolated from the. operating plant. d. (0 pen) Violation (445/8431-08 (a-c)): Procedural inadequacies in maintenance and records procedures. During an inspection of the above areas, inadequacies in the procedures controlling these activities were discovered. In the applicant's response several procedures were committed to revisions as the corrective action. To
. . .. -5- date, one of the procedures, STA-602, " Temporary Modifications and Bypassing of Safety Functions," has not been revised in the time frame stated in the applicant's response. Additionally, STA-606, " Maintenance Actions Requests," has been revised to the extent that it has changed method of procedural control of maintenance and has, in effect, made this part of violation 84-31-V-08a a closed issue. The new Procedure STA-606, " Work Requests and Work Orders," was reviewed as part of follow up to this violation. The comments are discussed in paragraph 3 below. This item remains open pending revision of STA-602. e. (Closed) Open Item (445/8439-02): During an NRC inspection conducted in October 1984, the inspector identified an apparent interchange of valve number prefixes between Revision 1 of System Operating Procedure 50P-103A, " Chemical Volume and Control System," and the system diagrams. For example, there were several cases where valves numbered, "1-XXXX" on the system diagram (and in the plant) were < identified in 50P-103A as "1CS-XXXX." This has since been corrected by Revision 2 of SOP-103A, which was issued on April 29, 1985. This item is closed. f. (Closed) Open Item (445/8439-03): During a review in October 1984 of Revision 1 of SOP-501A, " Station Service Water System," the NRC inspector noted that system diagram 2323-MI.0233, Revision CP-6, did not contain the valve numbers for chlorination valves identified by number in Section 5.4 of S0P-501A and Attachment 1 (valve lineup) Section 2.0. Upon reviewing Revision CP-9 to 2323-MI-0233, the RRI verified that all of the valve numbers in question had been added. This item is closed. g. (Closed) Open Item (445/8439-04): During an October 1984 review of 50P-609A, Revision 1, " Diesel Generator System," the NRC inspector identified inconsistencies throughout the procedure with regard to the name of the Auxiliary Lube Oil Pump. In the 17 places where the pump was mentioned, it was referred to as either the " Auxiliary Oil Pump," Auxiliary Lube Oil Pump," or " Auxiliary Oil Lub'e Pump." The applicant committed to correct this in the next revision. During.the followup inspection of SOP-609A, Revision 2, the RRI verified that the Auxiliary Lube Oil Pump appeared 19 times, and was correctly designated in 18 of 19 instances. One appeared as " Auxiliary Oil Pump," which is an insignificant disparity. This item is closed. h. (Closed) Open Item (445/8439-05): Also during the inspection of 50P-609A, the NRC inspector identified a missing step in- Section 5.3.1 of the procedure. Section 5.3.2, which detailed local normal shutdown of the emergency diesel generator, required reactive load to be reduced to approximately zero before opening the output breakers. Section 5.3.1, which describes the remote shutdown, did not have such a requirement. The applicant committed to revise -- - - . - , - ._ _-
. s . 4 -6- . , . . Section5.3.1toincludetherequirement.'_iheRRIhasTsinceverified that 50P-609A, Revision 2, contained the requirement. This item is closed. e s 44 e t i. (Closed) Open Item (445/8439-06): . During an inspectioniofvInitial~ Startup Administrative Procedure ISA-004, Revision 1, " Conduct of Initial Startup Testing," the RRI identified a problem withi Section 4.2.6 which appeared to allow, operations personnel to operate plant safety-related equipment using draft procedures'for.the purpose of grooming the procedures. The applicant responded by, assuring the RRI that the intent was to conduct dry runs only, and that plant equipment would be operated in accordance with approved procedures. The RRI has since inspected ISA-004, Revision 2, which was issued on April 1, 1985. Section 4.2.6 has been revised to delete reference to the use of_ draft procedures and clarified the requirement to use- aporoved procedures with prescribed change controls during trial runs. This item is closed. j. (Closed) Open Item (445/8439-07): While reviewing ISA-004, Revision 1, the RRI noted that Section 4.4.2.1 allowed QA to waive previously established test conduct surveillances and the reason or justification did not have to be recorded in the test procedure and data package. The RRI was concerned that the basis for this apparent degradation in QA surveillance needs to be evaluated to ensure that test integrity will not be compromised. The applicant subsequently explained that test integrity is not compromised by waiving selected QA surveillances, because QA makes the decision, and no,t anyone directly responsible for the conduct of the test. Furthermore, the QA Initial Startup Training Handbook, an internal QA document, has required the reason for waiving a surveillance to be recorded on the QA Data Sheet used during the surveillance. ISA-004 has also been revised (Revision 2, dated April 1, 1985) such that the test log shall contain the bases for QA waiving of surveillance and what steps in the test procedure were waived. This provides the controls sought by the RRI and thus the item is closed. k. (0 pen) Unresolved Item (445/8422-06): On June 27, 1984, the SRRI identified that a potential design problem existed in the safety-related battery rooms. The primary concern was that the exhaust duct intake registers were below large overhead pockets , (approximately 4 feet high, 6 feet wide, and 21 feet long) where it appeared that hydrogen could collect and accumulate in concentrations in excess of safe limits. The applicant recommended closure of this item on the basis of an unsupported statement that the hydrogen generated by the batteries will diffuse in air and not stratify, therefore, no exhaust duct routing problem exists. This was ' discussed with a member of the NRC Fire Protection Analysis Team, who , considers this to remain an unresolved issue pending receipt of more ' information from the applicant. Therefore, this item shall remain open. There is a related unresolved issue described in paragraph 4 4 ' of this appendix which addresses an additional concern that nonsparkproof thermostats were installed in the battery rooms. _ , , .. - - _ .~. ._ . , , __. -.
-7- . 3. Review of Station Administrative Procedure STA-606 As stated in paragraph' 2.d above, STA-606 was reviewed during the NRC followup inspection of the applicant's response to violation 445/8431-V-08(a-c). - ' _ STA-606 was originally entitled, " Maintenance Actions _Requ'ests," and is now entitled, " Work Requests and Work Orders." Maintenance' action _ requests (MARS) are no longer used. They have been replaced with Work. Requests (WRs) and Work Orders (W0s). During the proce' dure revies, the; following areas appeared to be inadequate: ' a. In Section 4.2.2.2.1.2, the note appears to give the shift supervisor- the authority to bypass the QC function under emergency. 1 (Priority 11) conditions. It would appear that either the present . aefinition of what constitutes an emergency repair condition needs to be more narrowly defined, or the authority to bypass the QC function. should not be given to the shift supervisor.- b. Section 4.8.2 gives the shift supervisor authority to " add / change / delete" post-test requirements. It appears that this would constitute a change to a W0 after the review and approval cycle had been completed. This section does not require that the shift supervisor's changes be reviewed as required under Sections 4.7.1 and 4.7.2. This action by the shift supervisor, especially by changing or deleting post-test requirements, could have far reaching effects on equipment operability. c. Section 4.5.1 does not appear to provide guidance to assure " complete and accurate" job documentation. . d. In Section 4.6.3.4, it appears that the approval to start work when troubleshooting should require the same level of release from the shift supervisor as the release to start work of a detailed work order. This item is considered unresolved pending further discussion with the applicant (445/8601-U-01). Review of this procedure will continue during a subsequent inspection. 4. Miscellaneous Independent Inspections a. During an independent inspection of the station safety-related battery rooms, the RRI noticed that the thermostats which control the space heaters were mounted on the walls inside the battery rooms and did not appear to be explosion proof. It was later confirmed by QA that the thermostats were not designed to be explosion proof.
Section 14 of ANSI C2, 1977, the National Electrical Safety Code, states that if heater thermostats are installed in battery rooms, they should be in explosion proof housings. The primary concern is if the battery room ventilation fails, and the heaters cycle on, -- --_- - . . _ . _ . . . _ _ _
-8- there is no assurance that the atmosphere in which the thermostats function will be within safe hydrogen concentrations, and thus an explosion hazard appears to exist. Disposition of this issue will be an unresolved item pending applicant's review of this issue and discussions between the RRI and NRC Fire Protection personnel (445/8601-U-02). b. While inspecting the 773 foot elevation of the Unit 1 Safeguards Building, the NRC inspector noticed that Component Cooling Water manual valves ICC-137 and ICC-145 were reversed from the locations shown on isometric Drawings GHH-CC-1-SB-027, Revision 6, and GHH-CC-1-SB-040, Revision 12. Upon tracing the lines to their destination, the valve label plates appeared correct as to function. Consequently, there was no operational problem; however, the drawings did not correctly show the location of the valves with respect to the piping and adjacent structure. System diagram 2323-MI-0229, Revision CP-4, appeared to agree with the isometrics but the drawing
is functionally correct. The applicant confirmed the error and has committed to correct the drawings. Since the valves are labeled correctly and perform the intended functions, there.is no safety significance to this discrepancy. Correction of the appropriate drawings shall be tracked as an open item (445/8601-0-03). c. The RRI conducted a followup inspection to gain an understanding of the underlying problems associated with a potential.10 CFR. Part 50.55(e) reportable deficiency with the turbine driven auxiliary feedwater (TDAFW) pump. The problem related to'a. system design change in 1983, where a larger miniflow line restricting orifice was installed to correct unacceptable piping movements at low: flows resulting from low flow frequency harmonics of the system. This change increased the pump bypass flow (miniflow)1from 45_to ' 100 gallons per minute (GPM), which decreased the flow to the point where the pump capacity appeared inadequate ^to meet the minimum flow required by the Technical Specifications (TS). The RRI noted that the preoperational test for the motor driven auxiliary . , feedwater (MDAFW) pumps and the TDAFW pump did'not support the head requirements of the final draft TS, and the-FSAR was~in' conflict with both the preoperational tests and the-final draft TS. The applicant identified all of the disparities (except the one described below) and is taking appropriate corrective actions, which will be presented to the NRC via amendments to the FSAR, procedure changes, and TS change requests. The problem not identified by the applicant was that preoperational tests 1CP-PT-37-01, " Auxiliary Feedwater System (Motor Driven Pumps)," and 1CP-PT-37-03, " Auxiliary Feedwater System (Turbine Driven Pump)," failed to test the MDAFW and TDAFW pumps against the maximum back pressure specified in the FSAR. The preoperational tests operated the pumps against a back pressure equivalent to the setpoint of the lowest set main steam safety valve plus system frictional and static losses, instead of the requirement of FSAR Section 10.4.9.1 to operate against a back pressure equivalent to the accumulation pressure of the lowest set main steam
-9- safety valve plus system frictional and static losses. The accumulation pressure is addressed in FSAR Section 10.3.2 and the difference amounts tc a pump head increase of about 80 feet. The significance of this issue is that the pumps were not proved to deliver the minimum required flow at this higher head. This test problem is a deviation from the conditions prescribed in the FSAR (445/8601-D-04). d. Also, while reviewing the auxiliary feedwater system diagrams, the RRI noted that FSAR Section 10.4.9.2 mentions single lines supplying water to the MDAFW and TDAFW pumps through locked open valves. System diagram 2323-M1-0229 shows all manual valves between the condensate storage tank (CST) and the steam generators locked open; however, the 6-inch test bypass valves, which are capable of diverting all the flow back to the CST, are not locked shut. This appears to defeat the intent of the design to lock normal valves in their required position to assure flow to the steam generators in an emergency. The applicant acknowledged this finding and agreed that it would be prudent to require each of the three test bypasses to be locked closed. The valves are 1AF-042, 1AF-055, and 1AF-067. Incorporation of this into System Operating Procedure 50P-304, operations surveillance test OPT-206, and auxiliary feedwater system diagram 2323-M1-0229 shall be tracked as an open item (445/8601-0-05). 5. Preventive Maintenance (PM) Programs The RRI is conducting an ongoing independent 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. The NRC inspector intorviewed applicant representatives responsible for the implementation and tracking of preventive ma'intenance and' reviewed computerized PM printouts and other records to determine theistatus of"the , l program. The NRC inspector also reviewed two QA audit's (TUG-40, conducted November 28 through December 2, 1983, and TUG-85-01,1 conducted in e'arly. l 1985), one construction project evaluation performed by theilnstitute of I Nuclear Power Operation (INF0) in August 1985, and site-QA Surveillance Report QSR-85-027 conducted between August 14 and September 20,.1985. The overall content of these reports indicated that the PM program at- l CPSES may have been fragmented, that some scheduled PM items were not; being done, and some components did not have the appropriate PM items ' l identified and scheduled upon turnover from construction to startup, which is required by MDA-301, " Preventive Maintenance Program." The NRC inspector patterned his reviews to gain a thorough understanding of the CPSES PM Program such that he could independently determine its adequacy. Four specific safety-related components were selected for an .in-depth review. The review consisted of (1) a c6mparison between the l L;
. -10- applicable surveillances in the final draft TS and the master surveillance test list (MSTL) to ensure that an implementing procedure was written for each; (2) a review of the applicable surveillance procedures for adequacy and technical correctness; (3) a comparison between the PM items recommended by the Westinghouse Managed Maintenance Guidelines manuals and the component technical manuals, and the PM items and frequencies listed in the applicant's Managed Maintenance Computer Program (MCP) database; (4) a review to see if the PM items were scheduled, accomplished as scheduled, or if not, why not; and (5) a visual inspection of the components to verify that hardware was not damaged or otherwise obviously uncared for, oil levels and purity were being maintained, and that the components were being kept clean commensurate with duty. The results of this review are detailed below: a. Centrifugal Charging Pump No. 1 (Tag No. TBX-CSAPCH-01): The TS surveillance procedures referenced by the MSTL were approved and issued; thus, there were procedures which covered the surveillance requirements listed in the TS for this pump. No problems were identified upon reviewing the procedures. , The MMCP printout appeared to identify all of the PM. items contained in the vendor technical manual and the Westinghouse Managed- Maintenance Guidelines manual. Of the 12 PM items identified for ' this component, only 5 were flagged as " active", meaning that those PM items were to be performed at the specified frequency in accordance with the procedures listed. The applicant's representative explained that the MMCP database ~ contained all of the PM items that will eventually apply to.each component, but they.would not all be placed in an " active" status until after the plant becomes- fully operational. The current " active" PM items'were selected by Maintenance Engineering to maintairi the equipment in the state of readiness required in the current cold shutdown,.'relicenser- p condition, and it appeared to be adequate.
One of the " active" items (insulation resistance checks on the motor) was to be done annually but was not accomplished in 1985. The applicant's representative could not offer a satisfactory explanation as to why the item had not been completed on time. MDA-301, " Preventive Maintenance Program" Revision 5, Section 4.3.3 requires. . every effort . " to be made to complete PM activities on " .. .. schedule. This delay did not appear justified, however, ". . . every effort . . ." is a difficult deaaline to enforce. This terminology ~ is one example of a lack of specificity contained in MDA-301 which is addressed in the conclusions below. b. Component Cooling Water Pump No. 2 (Tag No. CP1-CCAPCC-02): Review of the MSTL and surveillance procedures associated with this pump identified two documents not yet published. They were engineering surveillance tests EGT-770A and EGT-771A. Section 2.0 of operations surveillance test OPT-208A was missing a block of words. The first sentence did not identify what each valve was servicing, but it ___. _ _ .-. - _ , _ _ _ _ . . _ . . _ __
-11- appeared that the original author intended for it to do so. The issuance of EGT-770A and EGT-771A, and the correction of OPT-208A shall be tracked as an open item (445/8601-0-06). The MMCP database reflected all of the recommendations of the Westinghouse Managed Maintenance Guidelines manual and the component technical manual. There were 26 PM items-identified and, at the time of this inspection, 14 were designated as " active." Two PM items (a quarterly vibration check and an 18-month polar index check) were not being done. The applicant's representative explained that these originated from equipment qualification requirements and were being deferred until fuel load or as soon as the equipment vibration program was finalized, whichever occurs first. In light of the continuous service provided by the CCW pumps during this phase of construction, the RRI expressed concern that vibration checks should have been done as scheduled. The applicant acknowledged this at the exit interview. This concern shall be tracked as an unresolved item -(445/8601-U-07). There were no problems found during the visual inspection of the CCW pump. c. 125 VDC Safeguards Station Battery (Tag No. CP1-EPBTED-01): Review of the MSTL and surveillance procedures confirmed that adequate surveillance requirements have been implemented. The.RRI payed particular attention to the pitfalls that can be _ experienced in station battery care which were identified'at other nuclear power plants, such as improper use of basic battery parameters, and failures to conduct all of the required TS surveillances. One surveillance test procedure, however, did have a minor problem. EMP-710, " Battery Performance Discharge Test," covers the 18-month TS surveillance (TS 4.8.2.1.f) test requiring a discharge test of battery capacity when the battery shows signs'of' degradation or~has reached 85% of its expected service life for.the;applicatio_n. The acceptance criteria in EMP-710 did not appear to address the TS requirements for " operability." The applicant's maintenance representative committed to provide a response to this' problem, thus it will be tracked as an open item (445/8601-0-08). ~ ~ The MMCP database contained 12 PM items for the ba'tery which t appeared consistent with the Gould manual and the Westinghouse Managed Maintenance Guidelines. Two of the 12 items were designated " inactive." These items were weekly pilot cell checks and monthly battery inspections. When questioned by the RRI, the applicant's representative explained that these items were covered elsewhere by implementation of a " Standard Task List (STL)." The STL is a document used to identify routine, repetitive PM tasks that apply to large numbers of components and are within the expertise of the crafts who perform them. The RRI found it somewhat confusing to have the PM program fragmented in this manner, but upon review of the completed STLs in the records center, it appeared that these routine
-12- PM items were being done, but it was not evident that all of them were being done on time. The physical appearance and cleanliness of all of the battery rooms in Unit 1 reflected excellent care. d. Motor Driven Auxiliary Feed Pump No. 2 (Tag No. CP1-AFAPMD-02): While reviewing the applicable surveillance test procedures, the RRI identified problems with Operations Test Procedure OPT-206A, " Auxiliary Feedwater System Operability Test." Acceptance criteria, paragraph 10.5.3 required 940 GPM delivery from the TDAFW pump and 470 GPM delivery from the MDAFW pumps at a discharge pressure which was less than the total head requirements of TS 4.7.1.2.a. In each case, it appeared that pump suction pressure was not considered because the data sheets did not require suction pressure to be recorded. This parameter is necessary in order to calculate the ' total head under which the pumps are operating. The discharge pressure in the acceptance criteria nearly equates to a total head that would exist if suction " essure were essentially zero. Preoperational test data indicated suction pressures of roughly 20 psig. OPT-206A, Attachment 3 valve lineup requires the TDAFW pump test isolation valve 1AF-042 to be " locked open" when it should be closed. This is in conflict with OPT-206A acceptance criteria, paragraph 10.3, System Operating Procedure SOP-304, and the system diagram. The disposition of this valve is also addressed in paragraph 4 of this report. Corrections of these and other deficiencies were already in process, according to the applicant's operations representative, thus revision of OPT-206A shall be tracked as an open inspection item (445/8601-0-09). The MMCP databaee identified 27 PM items for the MDAFW pump and motor. These items were consistent with the' guidelines provided by - the vendor and the Westinghouse Managed Maintenance Guidelines manuals. Of the 27 line items, 11 were designated as " active" and though difficult to determine, it appeared that most were being - accomplished. ~ t
Despite detailed descriptions by the applicant's representatives of how j the PM program was structured at CPSES, it was not possible for the RRI' to reach definitive conclusions as to PM program' adequacy'from turnover to- startup to the present shutdown conditions. The essential elements appeared to be in place, but because MDA-301 contained.such a widespread use of words like, "may, should, every effort,-periodic, normally, and discretion," it appeared that the system did not implement a prescribed program with specific requirements which must be followed. The program appeared to be missing the discipline to require specific PM items, and to require when they must be done. This subject was discussed with applicant management at the exit interview. It remains unresolved whether or not an adequate PM program has been in place, commensurate with plant conditions. . - . -.
-13- The applicant committed to identify with documented evidence (1) what PM items were required since the above four components were released to startup; (2) when they were done, and by what procedure; and (3) if not done, what the justification was (445/8601-U-10). 6. 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: Work in progress was being accomplished using approved procedures o Special precautions for protection of equipment were implemented, o and additional cleanliness requirements were being adhered to for maintenance, flushing, and welding activities Installed safety-related equipment and components were being o protected and maintained to prevent damage and deterioration. 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 ' o Tests in progress < o Documentation of problems which arise during operating shifts. , Noviolationsordeviationswereidentified;however,therewbrefindings identified in paragraph 4 of this report. 7. Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 3, 4, and 5. 8. Plant Status as of January 31, 1986 , a. Unit No. 1 is reported to be 99% completa; however, during this inspection period it was discovered that the construction completion date specified in Construction Permit (CPPR-126) has passed. Effective January 29, 1986, the applicant placed a stop work order on
/ -14- . , Unit 1 construction activity and requested, extension of the date. On February 10, 1986, the NRC issued an order _ extending.the date to , August 1, 1988, and thus work was resumed. , - , ,. > .. , b. Unit No. 2 is reported to be 77% complete. The preoperational test program on systems associated with NRC inspections has not-yet started; however, several test procedures,have been} published fo comment. . 9. Exit Interview ' " . -- ^" 9 An exit interview was conducted February 6, 1986, with the, applicant representatives identified in paragraph 1 of this appendix.- During this- interview, the operations resident inspectors summarized the scope and findings of the inspection. The applicant acknowledged the findings. 1 i I _ _ _ _ _ }}