ML20212P783
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| 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
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APPENDIX C
I
OPERATIONS INSPECTION REPORT
^
U.S. NUCLEAR REGULATORY COMMISSION
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. REGION IV
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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
Kelley,'Sdni3r~Residyht Reactor
'
D. L.~ Dat'e
Inspector (SRRI), Regiorf IV CPSES Group
(paragraphs 1, 2, 3, 5, 7, 8, and 9)
[ W. F. Smith, Resident Reactor Inspector (RRI)
SH 8/2.6 /86
Date
. Region IV CPSES Group l
(paragraphs 1, 2, 4, 5, 6, 7, 8, and 9) 3
-Approved: -
8uo M26 /86
I. Barnes, Chief, Region IV CPSES Group Date
8609030272 860829
PDR
G
ADOCK 05000445
PDR
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Inspection Summary
Inspection Conducted: November 1,1985, through January 31, 1986 ,
(Report 50-445/86-01)
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Areas Inspected: Routine, unannounced inspection of (1) application actions o'n-
previous inspection findings, (2) station administrative procedure,
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(3) miscellaneous independent, (4) preventive maintenance programs, (5)p 'lant,
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.
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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
i control of storage of quality material while work is in progress.
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.
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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
445/8506-02. In the case of 445/8506-02, an i' nadequate procedure was
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'
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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
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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
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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
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Section5.3.1toincludetherequirement.'_iheRRIhasTsinceverified
that 50P-609A, Revision 2, contained the requirement. This item is
closed. s e
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
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' 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.
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.
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). -
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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.
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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,
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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
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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 .
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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
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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
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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-
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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
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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
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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
t which
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
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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
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accomplished. t
j Despite detailed descriptions by the applicant's representatives of how
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.
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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:
o Work in progress was being accomplished using approved procedures
o Special precautions for protection of equipment were implemented,
and additional cleanliness requirements were being adhered to for
maintenance, flushing, and welding activities
o Installed safety-related equipment and components were being
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
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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
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