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{{Adams | |||
| number = ML20197E589 | |||
| issue date = 05/06/1986 | |||
| title = Insp Rept 50-445/86-05 on 860201-0331.Deviations Noted: Failure to Provide Documented Evidence That Min Maint Actions Performed on Component Cooling Water Pump B | |||
| author name = Barnes I, Kelley D, Smith W, Westerman T | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000445 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-445-86-05, 50-445-86-5, NUDOCS 8605150285 | |||
| package number = ML20197E544 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 11 | |||
}} | |||
See also: [[see also::IR 05000445/1986005]] | |||
=Text= | |||
{{#Wiki_filter:. . . . .. . . | |||
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APPENDIX B | |||
U.S. NUCLEAR REGULATORY C0tNISSION | |||
REGION IV | |||
i NRC Inspection Report: 50-445/86-05 Permit: CPPR-126 | |||
Docket: 50-445 Category: A2 | |||
Applicant: Texas Utilities Electric Company (TVEC) | |||
Skyway Tower | |||
400 North Olive Street | |||
i Lock Box 81 | |||
Dallas, Texas 75201 | |||
i Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 | |||
l | |||
Inspection At: Glen Rose, Texas | |||
] | |||
Inspection Conducted: February 1 through March 31, 1986 | |||
' | |||
Inspecto A /[ 2/P/_ | |||
D~. ' IIatC | |||
' | |||
L. Kell'eyT | |||
Inspector Seq)Gr | |||
(SRRI , RegRes | |||
n IV dent Reactor | |||
CPSES Group | |||
(paragraphs 1, 2, 3b, ,6,7) | |||
1a 1 6 | |||
W.' F. Smith, Resident Reactor Inspector (RRI) Date | |||
Region IV CPSES Group | |||
(paragraphs 1, 2, 3a , 4, 5, 6, 7) | |||
Reviewed By: % f/f/$'6 | |||
- | |||
I. barnes, Group Leader, Region IV CPSES Group Date | |||
Approved: MM84 | |||
T. F. Westerman, Chief, Region IV CPSES Group .Date | |||
Inspection Summary | |||
l | |||
Inspection Conducted: February 1 through March 31, 1986 (Report 50-445/86-05) | |||
Areas Inspected: Routine, unannounced inspection of (1) applicant actions on | |||
previous inspection findings, (2) miscellaneous independent inspection issues, | |||
8605150285 860507 | |||
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PDR ADOCK 05000445 : | |||
G PDR | |||
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(3) preventive maintenance programs, (4) plant tours, and (5) plant status. | |||
Results: Within the five aieas inspected, two deviations (failure to complete | |||
actions committed in responses to violations, paragraph 2; and failure to | |||
implement an adequate preventive maintenance program, paragraph 4) were | |||
identified. | |||
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DETAILS | |||
1. Persons Contacted | |||
Applicant Personnel | |||
***A. B. Scott, Vice President, Nuclear Operations | |||
***M. R. Blevins, Maintenance Superintendent - | |||
***D. E. Deviney, Operations QA Supervisor | |||
***R. A. Jones, Manager, Plant Operations | |||
***D. W. Braswell, Engineering Superintendent | |||
***R. R. Wistrand, Operations Superintendent | |||
***J. C. Smith, Operations Quality Assurance | |||
*J. J. Allen, Operations Engineer | |||
***M. J. Riggs, Operations Support Engineer | |||
*R. 'W. Clark, Operations Support | |||
***B. T. Lancaster, Administrative Superintendent | |||
C. L. Turner, Director, Nuclear Training | |||
R. Flores, Operations Engineer | |||
R. W. Haskovec, Licensing | |||
**C. E. Scott, Startup Manager | |||
S. N. Franks, Special Project and. Technical Support Lead | |||
D. Walling, Maintenance Engineer | |||
D. Davis, Maintenance Engineering Supervisor | |||
**G. M. McGrath, Special Project and Technical Support Lead | |||
**T. Jenkins, Operations Support Supervisor | |||
**T. L. Gosdin, Support Services | |||
- | |||
**R. A. Wistrand, Operations Superintendent | |||
**R. Smith, Operations Support Engineer * | |||
* Denotes applicant representatives present during exit interview of March 6, | |||
1986. | |||
** Denotes applicant representatives present,duri66 exit interview of April 3, | |||
1986. | |||
. | |||
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*** Denotes both exit interviews attended. | |||
The NRC inspectors also interviewed other applicant employee.s during this | |||
inspection period. | |||
2. Applicant Actions on Previous Inspection Findings , | |||
a. (Closed) Open Item 445/8431-12: . Administrative errors in warehouse | |||
receiving inspector qualification records. During a review of | |||
inspector qualification records, the NRC inspector noted that five of | |||
six inspector qualification. records contained errors such as missing | |||
~ ~ | |||
certification and practical factor signatures, and'other similar | |||
administrative errors. During this inspection period, the'SRRI , | |||
. | |||
* | |||
. | |||
4- | |||
reviewed the five certification files. All signatures were in the | |||
proper place, along with the correct supporting documentation. This | |||
item is closed. | |||
b. (Closed) Open Item 445/8436-06: During a review of Emergency | |||
Response Guidelines (ERG) procedures, the NRC inspector identified a | |||
concern that several of the ERGS had procedure steps requiring the | |||
operator to proceed to subsequent steps and then later return to | |||
where he left off without the benefit of a reminder or prompt. The | |||
applicant committed to consider this concern later when the ERGS were | |||
exercised on the control room simulator. The applicant has since | |||
conducted exercises on the simulator using the ERGS to diagnose and | |||
recove? from the following five major malfunctions: steam generator | |||
tube rupture, main steam isolation valve failure to shut during a | |||
ruptured steam generator, loss of primary coolant accident (LOCA), | |||
loss of feedwater induced LOCA, and main steam line rupture. The | |||
applicant informed the RRI that no missed steps or confusion resulted | |||
from the absence of such prompts in the ERGS and thus did not intend | |||
to revise the ERGS to incorporate them. The applicant stated, | |||
however, that the issue will be reconsidered if during future | |||
simulator exercises, the need for prompts is. indicated. This item is | |||
closed. | |||
c. (Closed) Open Item 445/8436-07: During a September 1984 inspection | |||
of ERGS, the NRC inspector noted that several of the procedure " Data | |||
Packages" were not- approved at the time of the review. " Data | |||
Packages" are documents which provide a cross reference between data | |||
that appears in the ERGS (i.e. , pressure and temperature setpoints, | |||
or flow values) and the source document; i.e., system diagrams, FSAR, | |||
or Technical Specifications. By design, the " Data Package" for each | |||
ERG was not to be finalized until the ERG achieved its final form, | |||
and that was after the ERG received Station Operations Review | |||
Committee (50RC) approval. Revision 4 of Operations Administrative | |||
Procedure ODA-204, " Preparation of Emergency Response Guidelines" | |||
more clearly defined-this approval process in contrast with earlier, | |||
less specific revisions reviewed by the original NRC inspector. | |||
During the followup inspection, the RRI noted that the " Data | |||
Packages" in question had all been approved, but there was a new | |||
revision to most of the ERGS which will eventually h, ave a revised and | |||
approved " Data Package."- This item is closed. | |||
d. (0 pen) Open Item 445/8436-08: During an inspection of ERGS, the NRC | |||
inspector identified several cases where data was missing and | |||
snnotated as "later." The applicant indicated that the data was | |||
being generated by a computer simulation of the program and would be | |||
available in early October 1984. .The procedures were.r.eviewed by the | |||
RRI in February 1986 as a followup and it was noted that all of the | |||
data had since been incorporated by a March 1985 revis'an, except | |||
that Figure 1 of ECA-3.1 still contained a "later" in lieu of the | |||
required data. The applicant explained that this particular figure | |||
was to be generated by Nuclear Engineering, and not the computer | |||
. | |||
. . __ _ | |||
* | |||
, | |||
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simulation, and that the information had not been provided yet. | |||
Therefore, this item will remain open until Figure 1 of ECA-3.1 is | |||
completed. | |||
e. (Closed) Open Item 445/8436-09: During a September 1984 inspection | |||
of ERGS, the NRC inspector identified seven specific discrepancies | |||
which the applicant committed to correct. The RRI conducted a | |||
followup inspection of the procedures where the discrepancies had | |||
existed and verified that they had all been subsequently revised and | |||
the corrections had been made. This item is closed. | |||
f. (Closed) Open Item 445/8502-04: Du. ring the preoperational test | |||
program for CPSES Unit 1, the RRI noted a tendency of system test | |||
engineers (STEs) to overly utilize minor on-the-spot changes of test | |||
procedures such that the complexity of the changes should have | |||
required formal revisions to be made. The applicant made several | |||
changes to the applicable startup administrative procedures to | |||
provide better control of this on Unit 2, and during any subsequent | |||
testing on Unit 1. This item is closed. | |||
g. (0 pen) Violation 445/8502-05: During an inspection of completed | |||
preoperational test data packages, the RRI identified two packages | |||
i where the STE had failed to follow the administrative requirements | |||
for changing test documents. In the response to the Notice of | |||
Violation dated October 10, 1985, the applicant stated under | |||
i " Corrective Steps Taken" that ". . . a Test Deficiency Report | |||
(TDR No. 4254) has been written to document this violation and it | |||
supplements these two data packages with clarifying information | |||
' | |||
relative to this violation." The committed date of full compliance | |||
was October 18, 1985; however, in February 1986 the RRI conducted a | |||
followup. inspection and found that TDR 4254 was written on | |||
October 1, 1986, as stated in the response, but did not find the.TDR | |||
filed in the records center with either of the test data packages. | |||
The applicant's representative explained that the TDR was spill | |||
pending Joint Test Group review and approval. This is a deviation | |||
from the. commitment made to the NRC to be in. full compliance by | |||
October 18, 1985, which includes filing the approved TDR with the | |||
test data packages in the records center. During fpilowup | |||
inspections'made in January 1986, a similar instan.ce surfaced where | |||
the applicant comitted to accomplish a given task but followup | |||
inspection revealed that it had not been done. In this instance, in | |||
response to Violation 445/8431-08, the applicant comitted to revise | |||
Station Administrative Procedure STA-602 by June 1, 1985. The | |||
* | |||
revised procedure was not published until March 5,1986(445/8605-D-01). | |||
h. (Closed) Unresolved Item 445/8502-10: During an NRC inspection of | |||
the completed preoperational test data package for ICP-PT-64-10 | |||
" Safeguards Relay Actuation Test," the RRI identified a test | |||
procedure deviation (TPD) which had 60 line items of change | |||
instructions with 61 line items of justifications. It appeared that | |||
, :. . | |||
*9 | |||
. | |||
" | |||
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instruction number 43 was inadvertently omitted but its applicable | |||
justification was not. The unresolved issue was whether or not the | |||
omission of the instruction had impacted the test. Upon | |||
investigating, the applicant illustrated that the changes justified | |||
in item 43 were in fact incorporated by instruction number 50. This | |||
was another example of misuse of "short form" TPD changes and | |||
pennanent currective actions have been adequately taken in response | |||
to Open Item 8502-04 as discussed above. This item is closed. | |||
i. (Closed) Violation 445/8506-03: Failure to provide adequate | |||
procedures. During the corrective action followup inspection of a | |||
deficiency report 85-012 involving the replacement of the shaf t seal | |||
on Reactor Coolant Pump No. 2, the RRI identified four instances of | |||
procedural noncompliance or inadequacy. The applicant committed in | |||
the written response, TXX-4585, dated October 11, 1985, to revise | |||
MDA-201, " Electrical and Mechanical Maintenance Procedures and | |||
Instructions," to ensure that all maintenance activities would be | |||
accomplished as specified in the approved procedure / instruction. In | |||
addition, STA-404, " Control of Deficiencies," was to be revised to | |||
improve the reporting of deficiencies and to require more information | |||
for better response and corrective action evaluation. The applicant | |||
also committed to training of maintenance personnel to the new | |||
requirements of MDA-201. | |||
The SRRI reviewed the procedure changes and the training files, and | |||
verified that the commitments had been met. This item is closed. | |||
j. (Closed) Open Item 445/8506-04: Failure to adequately disseminate | |||
lessons learned. During the corrective action followup inspection of | |||
deficiency report 85-012 (2.1 above), the RRI noted that the | |||
applicant had disseminated lessons learned to only the two | |||
maintenance mechanics involved with the seal replacement and not to | |||
all personnel who could be placed in a similar situation in the | |||
future. The applicant subsequently repeated the training for all | |||
mechanical maintenance personnel. The SRRI reviewed the | |||
documentation and verified that the additional training had been | |||
accomplished. This item is closed. S | |||
k. (Closed) Unresolved Item 445/8514-01: During-a review of steam | |||
generator water chemistry records, the RRI identified a period of | |||
over 3 months when the steam generator pH was lower than required by | |||
. | |||
- | |||
procedure. Although the condition was eventually corrected, the | |||
RRI's concern was potential degradation of the wetted surfaces in the | |||
steam generators. Westinghouse later published a letter (WPT-8137 | |||
dated January 8, 1986) describing the scenario and stating that | |||
" | |||
. . . it is not believed that the occurrence (low pH for over 3 months | |||
while in ucid wet layup) would have resulted in excessive corrosion | |||
product accumulation in the steam generators within the period of the '' | |||
reported chemistry upset." This item is closed. | |||
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e | |||
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-7- | |||
3. Miscellaneous Independent Inspection Issues | |||
a. Review of System Operating Procedure | |||
The RRI conducted a detailed review of System Operating Procedure | |||
50P-607A, Revision 4, "118V AC Distribution System and Inverters." | |||
Comparisons were made with the actual hardware in the plant and with | |||
the vendor technical manual tn verify that the procedure was | |||
technically correct. The results of this inspection identified the | |||
following examples where the procedure was incorrect: | |||
(1) Section E.1 (First NOTE) incorrectly specified 465 volts, which | |||
reflected what was in the nonplant specific technical manual, | |||
but should have been 485 volts for CPSES. | |||
(2) Section E.1 (Second NOTE) specified 495.5 volts, which appeared | |||
incorrect. The applicant's representative could not justify the | |||
value and indicated it probably should have been 485 volts. | |||
(3) Section E.2 switch nomenclature did not match the installed | |||
equipment nameplate. | |||
(4) Section E.3 was missing a clarifying note that should have been | |||
transcribed from the vendor technical manual. | |||
The applicant's representative comitted to -review the entire | |||
procedure in detail and correct all such errors, and commented that | |||
there is a program under way to " fine tune" all system operating | |||
procedures which will correct such problems, if any, in other | |||
procedures. Completion of this procedure update shall be an open | |||
item (445/8605-0-02). | |||
b. Unit 1 Service Water System Deficiency | |||
On January 24, 1986, the applicant verbally notified the NRC of a | |||
potentially reportable item under the provisions of 10 CFR 50.55(e). | |||
The deficiencies reported were (1) weld failures; and (2) plasite | |||
coating failures. | |||
The applicant's investigation to date indicates the following: | |||
- | |||
(1) Weld Failure Evaluation | |||
(a) Two suspected weld problems in the spool piece downstream | |||
of flow control valve 1-SW-023 were determined to be | |||
erosion of base metal at the weld due to flow turbulence. | |||
In addition, there appeared to be-galvanic corrosion in the | |||
area near the valve (valve i-s stainless steel; piping is | |||
carbon steel). Due to the flow turbulence the plasite | |||
, | |||
coating was eroded away and then any protective oxide film | |||
, | |||
.. | |||
' | |||
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-8- | |||
that might have formed was continuously washed away. The | |||
spool piece is to be replaced with one that will resist | |||
this kind of failure. | |||
(b) Weld failure in the vicinity of instrument isolation valve | |||
1-SW-026 has been evaluated and appears to have been caused | |||
by flow induced vibration. The short pipe nipple had | |||
insufficient flexibility and thus a stress riser existed at | |||
the weld. The nipple was removed and replaced with a | |||
longer section of pipe. Reanalysis shows no stress riser | |||
at the repaired weld location. | |||
(c) A pinhole leak adjacent to field weld 10a on line | |||
2-SW-1-302-150-3 is suspected to have been caused by a | |||
welding process problem. A temporary patch has been placed | |||
over the hole to stop the leak. Further investigation will | |||
be made when the system can be removed from service. | |||
(2) The plasite coating failures appear to be limited to the areas | |||
of flow turbulence. In most of the system pipe runs where | |||
turbulence was not present, the coating showed no apparent | |||
deterioration after 8 years of service. The internal pipe | |||
inspection is nearly complete on Train A. Inspection of Train B | |||
(and both trains on Unit 2) will follow. | |||
(3) In addition to the specific repairs identified above, the | |||
applicant is considering the following additional actions: | |||
(a) Recoat any areas where the plasite coating has eroded with | |||
a more turbulence-resistant material. | |||
(b) Monitor for wall thinning in selected areas of the system | |||
where corrosion or erosion is most likely to occur, using | |||
ultrasonic testing methods. Some base line data has | |||
, already been recorded. | |||
4. Preventive Maintenance (PM) Programs | |||
The RRI has been conducting a comprehensive review of the PM programs at | |||
CPSES. Particular attention was focused on what programs have been in | |||
place to susta'in the level of quality required of safety-related , | |||
- | |||
structures, systems and components such that they will perform their | |||
intended functions. This is required by American National Standard | |||
N18.7-1976, which is an FSAR commitment through Regulatory' Guide 1.33. | |||
This aspect of preventive maintenance is significant at CPSES, due to the - | |||
extensive shutdown period currently being experienced. Resul.ts of other - | |||
aspects of the inspection are identified in NRC Inspection Reports | |||
445/85-13, 85-14, and 86-01. | |||
During this inspection period, the RRI reviewed the applicant's submittal . | |||
. | |||
of PM data in response to a request for documented e'idence | |||
v on (1) what PM | |||
. | |||
_ _ _ _ _ _ _ _ _ _ _ _ | |||
- | |||
* | |||
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_g. | |||
items were required since four safety-related components sampled by the | |||
RRI were released from construction to the startup testing organization, | |||
(2) when they were done, and by what procedure, and (3) if not done, what | |||
the justification was. The request was documented in NRC Inspection | |||
Report 445/86-01 as Unresolved Item 445/8601-U-10. Based on a review of | |||
the documentation provided by the applicant, the RRI identified the j | |||
following discrepancies, which were discussed in various meetings with j | |||
Maintenance Department representatives and at the exit interview of I | |||
April 3, 1986. | |||
a. Component Cooling Water Pump No. 2 (CP1-CCAPCC-02): | |||
Monthly motor rotation was not done from the component turnover date | |||
of April 30, 1981, until January 26, 1984. Quarterly pump rotation | |||
(which normally would have been done concurrent with motor rotation) | |||
was aise not done from turnover date of May 13,1981, until | |||
January 26, 1984. Monthly heater checks were not done from | |||
September 10, 1982, until January 14, 1985. | |||
l | |||
b. Station Battery (CP1-EPBTED-01): | |||
There was no documented evidence of weekly battery i'nspections from | |||
the time the battery was released on October 29, 1979, through | |||
May 21, 1982. According to the information furnished, this period | |||
was interrupted by turnovers back to construction for modifications, | |||
thus the entire period may not apply to the Operations Maintenance | |||
Department for responsit,ility. | |||
c. Motor Driven Auxiliary Feed Pump No. 2 (CP1-AFAPMD-02): | |||
The quarterly rotation was not done from September 27,1982, until | |||
August 18, 1984. | |||
d. Centrifugal Charging Pump No. 1 (TBX-CSAPCH-01): | |||
Pump / motor rotation was not done between March 25,1983, and | |||
February 25, 1984, and between February 25, 1984, and April 3,1985. | |||
The potential for quality degradation may be mitigated by the. fact that at | |||
' | |||
times during the above periods when the PMs were rdportedly not done (or | |||
at least not documented), the equipment was in operatf ori*or under test. | |||
The concern is that failure to produce documentation indicating conth.uity | |||
in basic PM activity (such as periodic inspections, equipment rotation and | |||
heater checks) in four out of four selected components is ind.icative of | |||
program weaknesses. Of particular concern are those systems which are not | |||
routinely operated during cold shutdown conditions. Failure to implement | |||
an adequate PM program is a deviation from-the FSAR commitment to comply | |||
with ANS N18.7-1976 (445/8605-D-03). This deviation supersedes and | |||
therefore closes Unresolved Item 445/8601-U-10. | |||
* | |||
. | |||
-10- | |||
5. 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 and welding activities; and | |||
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 supervisor's log books. Key items in the log review were: | |||
o Plant status, | |||
o Changes in plant status, | |||
o Tests in progress, and | |||
o Documentation of problems which arise during operating shifts. | |||
During the control room inspection tour conducted on March 25, 1986, the | |||
SRRI identified a degradation of cleanliness of the bench-top surfaces of | |||
the main control panels and in. particular the Unit 2 nuclear instrument | |||
panels. The nuclear instrument panels were open, but the instrument | |||
drawers had not yet been installed, thus there was no apparent equipment | |||
damage. The presence of dust and grit was caused by the extensive | |||
grinding activity above the control panels on control room ceiling | |||
structure which was under modification. There appeared to be enough | |||
protection in place, but this was not adequately supplemented by increased | |||
cleaning activity in the control room. The RRI followed up on March 26, | |||
1986, by inspecting the internals of the main control panels and noted a | |||
heavy layer of dust, but the presence of grinding grit was not evident. | |||
Control room cleanliness was discussed with the Operations Superintendent | |||
at the time of the inspection and again with attendees at the April 3, | |||
1986, exit interview. Actions to correct the condition were promptly | |||
implemented. The resident inspectors will continue to monitor this area - | |||
on future tours. | |||
6. Plant Status as of March 31, 1986 | |||
a. Unit No. I remains at 99% complete. Excavation and turbine building | |||
wall removal in preparation for replacement of condenser tubing has | |||
j | |||
, . . . , | |||
-11- | |||
been completed. A significant amount of pipe support rework is in | |||
progress and/or in the planning stage. | |||
b. Unit No. 2 is now 80% :omplete. Preoperational testing of | |||
safety-related systems has not commenced; however, test procedures | |||
are being generated. | |||
7. Exit Interview | |||
Exit interviews were conducted March 6,1986, and April 3,1986, with the | |||
applicant representatives identified in paragraph 1 of this appendix. | |||
During these interviews, the operations resident inspectors summarized the | |||
scope and findings of the inspection. The applicant acknowledged the | |||
findings. | |||
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. _ _ . _ . _ _ _ . _ . . _ . . , _ .._ - _ . . . _ _ _ . _ _ _ . _ _____.___m___ _ _ .___. ._. ____ _ _ _ _ . _ __._________ _ _ _ __._. | |||
}} |
Latest revision as of 08:18, 2 January 2021
ML20197E589 | |
Person / Time | |
---|---|
Site: | Comanche Peak |
Issue date: | 05/06/1986 |
From: | Barnes I, Kelley D, Will Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20197E544 | List: |
References | |
50-445-86-05, 50-445-86-5, NUDOCS 8605150285 | |
Download: ML20197E589 (11) | |
See also: IR 05000445/1986005
Text
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APPENDIX B
U.S. NUCLEAR REGULATORY C0tNISSION
REGION IV
i NRC Inspection Report: 50-445/86-05 Permit: CPPR-126
Docket: 50-445 Category: A2
Applicant: Texas Utilities Electric Company (TVEC)
Skyway Tower
400 North Olive Street
i Lock Box 81
Dallas, Texas 75201
i Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1
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Inspection At: Glen Rose, Texas
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Inspection Conducted: February 1 through March 31, 1986
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Inspecto A /[ 2/P/_
D~. ' IIatC
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L. Kell'eyT
Inspector Seq)Gr
(SRRI , RegRes
n IV dent Reactor
CPSES Group
(paragraphs 1, 2, 3b, ,6,7)
1a 1 6
W.' F. Smith, Resident Reactor Inspector (RRI) Date
Region IV CPSES Group
(paragraphs 1, 2, 3a , 4, 5, 6, 7)
Reviewed By: % f/f/$'6
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I. barnes, Group Leader, Region IV CPSES Group Date
Approved: MM84
T. F. Westerman, Chief, Region IV CPSES Group .Date
Inspection Summary
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Inspection Conducted: February 1 through March 31, 1986 (Report 50-445/86-05)
Areas Inspected: Routine, unannounced inspection of (1) applicant actions on
previous inspection findings, (2) miscellaneous independent inspection issues,
8605150285 860507
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(3) preventive maintenance programs, (4) plant tours, and (5) plant status.
Results: Within the five aieas inspected, two deviations (failure to complete
actions committed in responses to violations, paragraph 2; and failure to
implement an adequate preventive maintenance program, paragraph 4) were
identified.
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DETAILS
1. Persons Contacted
Applicant Personnel
- A. B. Scott, Vice President, Nuclear Operations
- M. R. Blevins, Maintenance Superintendent -
- D. E. Deviney, Operations QA Supervisor
- R. A. Jones, Manager, Plant Operations
- D. W. Braswell, Engineering Superintendent
- R. R. Wistrand, Operations Superintendent
- J. C. Smith, Operations Quality Assurance
- J. J. Allen, Operations Engineer
- M. J. Riggs, Operations Support Engineer
- R. 'W. Clark, Operations Support
- B. T. Lancaster, Administrative Superintendent
C. L. Turner, Director, Nuclear Training
R. Flores, Operations Engineer
R. W. Haskovec, Licensing
- C. E. Scott, Startup Manager
S. N. Franks, Special Project and. Technical Support Lead
D. Walling, Maintenance Engineer
D. Davis, Maintenance Engineering Supervisor
- G. M. McGrath, Special Project and Technical Support Lead
- T. Jenkins, Operations Support Supervisor
- T. L. Gosdin, Support Services
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- R. A. Wistrand, Operations Superintendent
- R. Smith, Operations Support Engineer *
- Denotes applicant representatives present during exit interview of March 6,
1986.
- Denotes applicant representatives present,duri66 exit interview of April 3,
1986.
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- Denotes both exit interviews attended.
The NRC inspectors also interviewed other applicant employee.s during this
inspection period.
2. Applicant Actions on Previous Inspection Findings ,
a. (Closed) Open Item 445/8431-12: . Administrative errors in warehouse
receiving inspector qualification records. During a review of
inspector qualification records, the NRC inspector noted that five of
six inspector qualification. records contained errors such as missing
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certification and practical factor signatures, and'other similar
administrative errors. During this inspection period, the'SRRI ,
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reviewed the five certification files. All signatures were in the
proper place, along with the correct supporting documentation. This
item is closed.
b. (Closed) Open Item 445/8436-06: During a review of Emergency
Response Guidelines (ERG) procedures, the NRC inspector identified a
concern that several of the ERGS had procedure steps requiring the
operator to proceed to subsequent steps and then later return to
where he left off without the benefit of a reminder or prompt. The
applicant committed to consider this concern later when the ERGS were
exercised on the control room simulator. The applicant has since
conducted exercises on the simulator using the ERGS to diagnose and
recove? from the following five major malfunctions: steam generator
tube rupture, main steam isolation valve failure to shut during a
ruptured steam generator, loss of primary coolant accident (LOCA),
loss of feedwater induced LOCA, and main steam line rupture. The
applicant informed the RRI that no missed steps or confusion resulted
from the absence of such prompts in the ERGS and thus did not intend
to revise the ERGS to incorporate them. The applicant stated,
however, that the issue will be reconsidered if during future
simulator exercises, the need for prompts is. indicated. This item is
closed.
c. (Closed) Open Item 445/8436-07: During a September 1984 inspection
of ERGS, the NRC inspector noted that several of the procedure " Data
Packages" were not- approved at the time of the review. " Data
Packages" are documents which provide a cross reference between data
that appears in the ERGS (i.e. , pressure and temperature setpoints,
or flow values) and the source document; i.e., system diagrams, FSAR,
or Technical Specifications. By design, the " Data Package" for each
ERG was not to be finalized until the ERG achieved its final form,
and that was after the ERG received Station Operations Review
Committee (50RC) approval. Revision 4 of Operations Administrative
Procedure ODA-204, " Preparation of Emergency Response Guidelines"
more clearly defined-this approval process in contrast with earlier,
less specific revisions reviewed by the original NRC inspector.
During the followup inspection, the RRI noted that the " Data
Packages" in question had all been approved, but there was a new
revision to most of the ERGS which will eventually h, ave a revised and
approved " Data Package."- This item is closed.
d. (0 pen) Open Item 445/8436-08: During an inspection of ERGS, the NRC
inspector identified several cases where data was missing and
snnotated as "later." The applicant indicated that the data was
being generated by a computer simulation of the program and would be
available in early October 1984. .The procedures were.r.eviewed by the
RRI in February 1986 as a followup and it was noted that all of the
data had since been incorporated by a March 1985 revis'an, except
that Figure 1 of ECA-3.1 still contained a "later" in lieu of the
required data. The applicant explained that this particular figure
was to be generated by Nuclear Engineering, and not the computer
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simulation, and that the information had not been provided yet.
Therefore, this item will remain open until Figure 1 of ECA-3.1 is
completed.
e. (Closed) Open Item 445/8436-09: During a September 1984 inspection
of ERGS, the NRC inspector identified seven specific discrepancies
which the applicant committed to correct. The RRI conducted a
followup inspection of the procedures where the discrepancies had
existed and verified that they had all been subsequently revised and
the corrections had been made. This item is closed.
f. (Closed) Open Item 445/8502-04: Du. ring the preoperational test
program for CPSES Unit 1, the RRI noted a tendency of system test
engineers (STEs) to overly utilize minor on-the-spot changes of test
procedures such that the complexity of the changes should have
required formal revisions to be made. The applicant made several
changes to the applicable startup administrative procedures to
provide better control of this on Unit 2, and during any subsequent
testing on Unit 1. This item is closed.
g. (0 pen) Violation 445/8502-05: During an inspection of completed
preoperational test data packages, the RRI identified two packages
i where the STE had failed to follow the administrative requirements
for changing test documents. In the response to the Notice of
Violation dated October 10, 1985, the applicant stated under
i " Corrective Steps Taken" that ". . . a Test Deficiency Report
(TDR No. 4254) has been written to document this violation and it
supplements these two data packages with clarifying information
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relative to this violation." The committed date of full compliance
was October 18, 1985; however, in February 1986 the RRI conducted a
followup. inspection and found that TDR 4254 was written on
October 1, 1986, as stated in the response, but did not find the.TDR
filed in the records center with either of the test data packages.
The applicant's representative explained that the TDR was spill
pending Joint Test Group review and approval. This is a deviation
from the. commitment made to the NRC to be in. full compliance by
October 18, 1985, which includes filing the approved TDR with the
test data packages in the records center. During fpilowup
inspections'made in January 1986, a similar instan.ce surfaced where
the applicant comitted to accomplish a given task but followup
inspection revealed that it had not been done. In this instance, in
response to Violation 445/8431-08, the applicant comitted to revise
Station Administrative Procedure STA-602 by June 1, 1985. The
revised procedure was not published until March 5,1986(445/8605-D-01).
h. (Closed) Unresolved Item 445/8502-10: During an NRC inspection of
the completed preoperational test data package for ICP-PT-64-10
" Safeguards Relay Actuation Test," the RRI identified a test
procedure deviation (TPD) which had 60 line items of change
instructions with 61 line items of justifications. It appeared that
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instruction number 43 was inadvertently omitted but its applicable
justification was not. The unresolved issue was whether or not the
omission of the instruction had impacted the test. Upon
investigating, the applicant illustrated that the changes justified
in item 43 were in fact incorporated by instruction number 50. This
was another example of misuse of "short form" TPD changes and
pennanent currective actions have been adequately taken in response
to Open Item 8502-04 as discussed above. This item is closed.
i. (Closed) Violation 445/8506-03: Failure to provide adequate
procedures. During the corrective action followup inspection of a
deficiency report 85-012 involving the replacement of the shaf t seal
on Reactor Coolant Pump No. 2, the RRI identified four instances of
procedural noncompliance or inadequacy. The applicant committed in
the written response, TXX-4585, dated October 11, 1985, to revise
MDA-201, " Electrical and Mechanical Maintenance Procedures and
Instructions," to ensure that all maintenance activities would be
accomplished as specified in the approved procedure / instruction. In
addition, STA-404, " Control of Deficiencies," was to be revised to
improve the reporting of deficiencies and to require more information
for better response and corrective action evaluation. The applicant
also committed to training of maintenance personnel to the new
requirements of MDA-201.
The SRRI reviewed the procedure changes and the training files, and
verified that the commitments had been met. This item is closed.
j. (Closed) Open Item 445/8506-04: Failure to adequately disseminate
lessons learned. During the corrective action followup inspection of
deficiency report 85-012 (2.1 above), the RRI noted that the
applicant had disseminated lessons learned to only the two
maintenance mechanics involved with the seal replacement and not to
all personnel who could be placed in a similar situation in the
future. The applicant subsequently repeated the training for all
mechanical maintenance personnel. The SRRI reviewed the
documentation and verified that the additional training had been
accomplished. This item is closed. S
k. (Closed) Unresolved Item 445/8514-01: During-a review of steam
generator water chemistry records, the RRI identified a period of
over 3 months when the steam generator pH was lower than required by
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procedure. Although the condition was eventually corrected, the
RRI's concern was potential degradation of the wetted surfaces in the
steam generators. Westinghouse later published a letter (WPT-8137
dated January 8, 1986) describing the scenario and stating that
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. . . it is not believed that the occurrence (low pH for over 3 months
while in ucid wet layup) would have resulted in excessive corrosion
product accumulation in the steam generators within the period of the
reported chemistry upset." This item is closed.
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3. Miscellaneous Independent Inspection Issues
a. Review of System Operating Procedure
The RRI conducted a detailed review of System Operating Procedure
50P-607A, Revision 4, "118V AC Distribution System and Inverters."
Comparisons were made with the actual hardware in the plant and with
the vendor technical manual tn verify that the procedure was
technically correct. The results of this inspection identified the
following examples where the procedure was incorrect:
(1) Section E.1 (First NOTE) incorrectly specified 465 volts, which
reflected what was in the nonplant specific technical manual,
but should have been 485 volts for CPSES.
(2) Section E.1 (Second NOTE) specified 495.5 volts, which appeared
incorrect. The applicant's representative could not justify the
value and indicated it probably should have been 485 volts.
(3) Section E.2 switch nomenclature did not match the installed
equipment nameplate.
(4) Section E.3 was missing a clarifying note that should have been
transcribed from the vendor technical manual.
The applicant's representative comitted to -review the entire
procedure in detail and correct all such errors, and commented that
there is a program under way to " fine tune" all system operating
procedures which will correct such problems, if any, in other
procedures. Completion of this procedure update shall be an open
item (445/8605-0-02).
b. Unit 1 Service Water System Deficiency
On January 24, 1986, the applicant verbally notified the NRC of a
potentially reportable item under the provisions of 10 CFR 50.55(e).
The deficiencies reported were (1) weld failures; and (2) plasite
coating failures.
The applicant's investigation to date indicates the following:
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(1) Weld Failure Evaluation
(a) Two suspected weld problems in the spool piece downstream
of flow control valve 1-SW-023 were determined to be
erosion of base metal at the weld due to flow turbulence.
In addition, there appeared to be-galvanic corrosion in the
area near the valve (valve i-s stainless steel; piping is
carbon steel). Due to the flow turbulence the plasite
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coating was eroded away and then any protective oxide film
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that might have formed was continuously washed away. The
spool piece is to be replaced with one that will resist
this kind of failure.
(b) Weld failure in the vicinity of instrument isolation valve
1-SW-026 has been evaluated and appears to have been caused
by flow induced vibration. The short pipe nipple had
insufficient flexibility and thus a stress riser existed at
the weld. The nipple was removed and replaced with a
longer section of pipe. Reanalysis shows no stress riser
at the repaired weld location.
(c) A pinhole leak adjacent to field weld 10a on line
2-SW-1-302-150-3 is suspected to have been caused by a
welding process problem. A temporary patch has been placed
over the hole to stop the leak. Further investigation will
be made when the system can be removed from service.
(2) The plasite coating failures appear to be limited to the areas
of flow turbulence. In most of the system pipe runs where
turbulence was not present, the coating showed no apparent
deterioration after 8 years of service. The internal pipe
inspection is nearly complete on Train A. Inspection of Train B
(and both trains on Unit 2) will follow.
(3) In addition to the specific repairs identified above, the
applicant is considering the following additional actions:
(a) Recoat any areas where the plasite coating has eroded with
a more turbulence-resistant material.
(b) Monitor for wall thinning in selected areas of the system
where corrosion or erosion is most likely to occur, using
ultrasonic testing methods. Some base line data has
, already been recorded.
4. Preventive Maintenance (PM) Programs
The RRI has been conducting a comprehensive review of the PM programs at
CPSES. Particular attention was focused on what programs have been in
place to susta'in the level of quality required of safety-related ,
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structures, systems and components such that they will perform their
intended functions. This is required by American National Standard
N18.7-1976, which is an FSAR commitment through Regulatory' Guide 1.33.
This aspect of preventive maintenance is significant at CPSES, due to the -
extensive shutdown period currently being experienced. Resul.ts of other -
aspects of the inspection are identified in NRC Inspection Reports
445/85-13, 85-14, and 86-01.
During this inspection period, the RRI reviewed the applicant's submittal .
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of PM data in response to a request for documented e'idence
v on (1) what PM
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items were required since four safety-related components sampled by the
RRI were released from construction to the startup testing organization,
(2) when they were done, and by what procedure, and (3) if not done, what
the justification was. The request was documented in NRC Inspection
Report 445/86-01 as Unresolved Item 445/8601-U-10. Based on a review of
the documentation provided by the applicant, the RRI identified the j
following discrepancies, which were discussed in various meetings with j
Maintenance Department representatives and at the exit interview of I
April 3, 1986.
a. Component Cooling Water Pump No. 2 (CP1-CCAPCC-02):
Monthly motor rotation was not done from the component turnover date
of April 30, 1981, until January 26, 1984. Quarterly pump rotation
(which normally would have been done concurrent with motor rotation)
was aise not done from turnover date of May 13,1981, until
January 26, 1984. Monthly heater checks were not done from
September 10, 1982, until January 14, 1985.
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b. Station Battery (CP1-EPBTED-01):
There was no documented evidence of weekly battery i'nspections from
the time the battery was released on October 29, 1979, through
May 21, 1982. According to the information furnished, this period
was interrupted by turnovers back to construction for modifications,
thus the entire period may not apply to the Operations Maintenance
Department for responsit,ility.
c. Motor Driven Auxiliary Feed Pump No. 2 (CP1-AFAPMD-02):
The quarterly rotation was not done from September 27,1982, until
August 18, 1984.
d. Centrifugal Charging Pump No. 1 (TBX-CSAPCH-01):
Pump / motor rotation was not done between March 25,1983, and
February 25, 1984, and between February 25, 1984, and April 3,1985.
The potential for quality degradation may be mitigated by the. fact that at
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times during the above periods when the PMs were rdportedly not done (or
at least not documented), the equipment was in operatf ori*or under test.
The concern is that failure to produce documentation indicating conth.uity
in basic PM activity (such as periodic inspections, equipment rotation and
heater checks) in four out of four selected components is ind.icative of
program weaknesses. Of particular concern are those systems which are not
routinely operated during cold shutdown conditions. Failure to implement
an adequate PM program is a deviation from-the FSAR commitment to comply
with ANS N18.7-1976 (445/8605-D-03). This deviation supersedes and
therefore closes Unresolved Item 445/8601-U-10.
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5. 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 and welding activities; and
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 supervisor's log books. Key items in the log review were:
o Plant status,
o Changes in plant status,
o Tests in progress, and
o Documentation of problems which arise during operating shifts.
During the control room inspection tour conducted on March 25, 1986, the
SRRI identified a degradation of cleanliness of the bench-top surfaces of
the main control panels and in. particular the Unit 2 nuclear instrument
panels. The nuclear instrument panels were open, but the instrument
drawers had not yet been installed, thus there was no apparent equipment
damage. The presence of dust and grit was caused by the extensive
grinding activity above the control panels on control room ceiling
structure which was under modification. There appeared to be enough
protection in place, but this was not adequately supplemented by increased
cleaning activity in the control room. The RRI followed up on March 26,
1986, by inspecting the internals of the main control panels and noted a
heavy layer of dust, but the presence of grinding grit was not evident.
Control room cleanliness was discussed with the Operations Superintendent
at the time of the inspection and again with attendees at the April 3,
1986, exit interview. Actions to correct the condition were promptly
implemented. The resident inspectors will continue to monitor this area -
on future tours.
6. Plant Status as of March 31, 1986
a. Unit No. I remains at 99% complete. Excavation and turbine building
wall removal in preparation for replacement of condenser tubing has
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been completed. A significant amount of pipe support rework is in
progress and/or in the planning stage.
b. Unit No. 2 is now 80% :omplete. Preoperational testing of
safety-related systems has not commenced; however, test procedures
are being generated.
7. Exit Interview
Exit interviews were conducted March 6,1986, and April 3,1986, with the
applicant representatives identified in paragraph 1 of this appendix.
During these interviews, the operations resident inspectors summarized the
scope and findings of the inspection. The applicant acknowledged the
findings.
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