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#REDIRECT [[TXX-4854, Responds to NRC Re Deviations Noted in Insp Rept 50-445/86-05.Corrective Actions:Procedure STA-602 Revised Per 850319 Commitment,To Ensure Adequate Controls for Temporary Mods to safety-related Equipment]]
| number = ML20207E598
| issue date = 06/18/1986
| title = Responds to NRC 860507 Ltr Re Deviations Noted in Insp Rept 50-445/86-05.Corrective Actions:Procedure STA-602 Revised Per 850319 Commitment,To Ensure Adequate Controls for Temporary Mods to safety-related Equipment
| author name = Counsil W, Keeley G
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Johnson E
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| docket = 05000445
| license number =
| contact person =
| document report number = TXX-4854, NUDOCS 8607220379
| package number = ML20207E573
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 10
}}
 
=Text=
{{#Wiki_filter:.
  .                                                                                            Log # TXX-4854 File # 10130 IR 86-05 TEXAS UTILITIES GENERATING COMPANY NKYWAY TOWER . 400 NORTH OLIVE ErrREET. L.B. El
* DALLAS. TEXAS 78301 June 18, 1986
      ,*MCONY."&h
(    _
Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects D$@@@@                    h' l
U. S. Nuclear Regulatory Commission f ; M23M 4 H 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012
 
==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)                              - - . -
DOCKET NO. 50-445 RESPONSE TO NRC NOTICE OF DEVIATION INSPECTION REPORT N0.: 50-445/86-05
 
==Dear Mr. Johnson:==
 
We have reviewed your letter dated May 7,1986, concerning the inspection conducted by Messrs. D. L. Kelley and W. F. Smith of the Region IV Comanche Peak Group during the period February 1 through March 31, 1986. This inspec-tion covered activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Steam Electric Station Unit 1.
We requested and received a two week extension in providing our response during a telephone conversation with Mr. T. F. Westerman on June 6, 1986.
We have responded to the Notice of Deviation in the attachments to this letter.
Very truly yours,
[        be7ad[
W. G. C n il By:        ,
G. S. Keeley "
                                                                                                          &/
Manager,NuclearYicensing JCH/arh Attachments c - NRC Region IV (0 + 1 Copy)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonan Mr. D. L. Kelley 86072PO379 860716
{DR ADOCK 05000445    PDR A DEVEN10N OF TEXAN UTEUTIES EE.ECTRIC CU.HPANY
 
      .                                NOTICE OF DEVIATION ITEM A (445/8605-D-03)
A. The CPSES FSAR, Appendices IA(N) and 1A(B) commit the applicant to Regulatory Guide 1.33 which includes the requirements of American National Standard N18.7-1976/ANS-3.2. Section 5.2.7.1 of this standard states, "A maintenance program shall be developed to maintain safety-related struc-tures, systems, and components at the quality required for them to perform their intended functions."
In deviation from the above, the applicant failed to provide documented evidence that the minimum acceptable maintenance actions were performed on Component Cooling Water Pump No. 2, Train 8 Station Battery, Motor Driven Auxiliary Feed Pump No. 2, and Centrifugal Charging Pump No.1 during certain periods between the time these actions should have been implement-ed and the present. Minimum acceptable maintenance actions include such items as hand or operational rotation of rotating equipment, heater checks,and visual inspections on a prescribed periodic basis (445/8605-D-03).
RESPONSE TO ITEM A
: 1. REASON FOR DEVIATION The subject NRC notice expressed " concern . . . . that failure to produce documentation indicating continuity in basic PM activities . . . . in four out of four selected components is indicative of program weakness."
We will attempt to demonstrate that even though the PM program documenta-tion was not complete, as indicated by the RRI (Resident Reactor Inspector), that the quality of the equipment was either maintained, verified or restored through corrective maintenance, inspection, testing or satisfactory operation.
It appears that the primary cause of the PM documentation discrepancies was due to the program philosophy in place during this time period. At that point in time, PMs were only documented as complete when they were actually performed, but, the program also did not require performance of
.          the PM if some other condition satisfied the PM requirement. For in-l          stance, if a shaft rotation was required by the PM program and the worker found the pump operating, then he did not rotate the shaft. The worker indicated that the pump was running and the PM was rescheduled for the next interval, but credit was not taken for the shaft rotation even though l
I the pump was running. Therefore, the PM documentation shows a gap in the PM performance. Another example might be that a motor was removed for i
repairs for several months so the PM requirement for heater checks would l          simply show a gap until the motor was returned to the plant.
These types of circumstances have been accounted for in the revised PM program documentation.
In addition, the subject NRC notice identified six specific deviations from the FSAR commitment to comply with ANSI N18.7-1976 on four safety related components sampled by the RRI. These specific deviations have 7
been evaluated in detail by the CPSES Maintenance Department. The results of these evaluations are described below.
 
NOTICE OF DEVIATION ITEM A (445/8605-D-03)
(Continued)
: a. Component Cooling Water Pump 02 (CPI-CPAPCC-02) i The following is in response to the NRC's concerns regarding the PM
,                        activities on Train B Component Cooling Water Pump and Motor (CPI-CCAPCC-02/02M). The following two deviations were evaluated as one:
: 1. Failure to perform monthly motor rotation from the component j
turnover date of April 30, 1981, until January 26, 1984.
: 2. Failure to perform quarterly pump rotation from the component turnover date of May 13, 1981, until January 26, 1984.
l                        The intent of periodic shaft rotation is to prevent shaft warpage ano to ensure that bearing condition is properly maintained during extend-ed periods of inoperation. Therefore, if the pump / motor was operated
;                        or rotated for another purpose (i.e., coupling alignment), the objec-
;                        tive of periodic shaft rotation was met.
l                        This evaluation included a review of appropriate documentation from j                        the following sources:
l                        1. The Managed Maintenance Computer Program's (MMCP) maintenance guidelines for the pump /motnr.
: 2. The MOD's and MMCP's maintenance history listings for the periods 4                            listed above.
!                        3. All Maintenance Action Requests (MAR) and Work Orders (W0) generated for the pump and motor.
:                        The review revealed that the pump and motor were set and coupled on 4/28/81. Therefore, any rotation activities performed subsequent to this date satisfied both the pump and motor shafts rotation requirements. There is documentation to demonstrate that, during i                        periodic walkdown inspections, the subject equipment was found running and therefore shaft rotation was satisfied. To further support the fact that the equipment was being maintained adequately, two major
;                        motor teardown inspections (5/12/81 and 10/19/84) and two major pump r                        teardown inspections (5/19/81 and 2/27/84) were performed. These inspections confirmed that the pump and motor were in good operating condition.
i
!                        The third deviation in Report No. 40-445/86-05, Section 4.A identified i                        a failure to perform monthly heater checks from September 10, 1982 through January 14, 1985.
l
!                        The objective of performing heater checks is to verify that motor
!                        space heaters are operating during extended periods of motor shutdown.
This inhibits the information of condensation in the motor which could result in a degradation of motor insulation.
:                        A review of the previously listed sources revealed that during the
!                        period in question, the motor was meggered on three separate occasions l                        (8/10/83,5/7/84,10/19/84) without indication of insulation degrada-
'                      tion. This is further substantiated through the results of the k !
 
NOTICE OF DEVIATION ITEM A (445/8605-D-03)
(Continued) aforementioned motor teardown inspections.
In conclusion, the data confirms that, even though there is insuffi-cient documentation in the PM Program alone to demonstrate the perfor-mance of the subject PM activities,there is adequate evidence to prove that the quality of the equipment has been preserved through other programs, such as corrective maintenance or operation. In other words, the intended activity has been satisfied through other means.
: b. Station Battery (CPI-EPBTED-01)
The following evaluation was performed in response to the NRC's concerns regarding the PM program for the Train B Station Battery (CPI-EPBTED-01). The report identified the following deviation:
        "There was no documented evidence of weekly battery inspections from the time the battery was released on October 29, 1979, through May 21, 1982."
The basis for the PM activity is IEEE 450-1980, which requires an
        " inspection of the batteries on a regularly scheduled basis of at least once per month". This activity includes inspection of the pilot cell and recording of the following:
: 1.          float voltage,
: 2.          specific gravity,
: 3.          electrolyte temperature and level,
: 4.          battery float voltage,
: 5.          battery charger current, and
: 6.          total float voltage.
The intent of this battery inspection is to identify battery degradation.
This evaluation included a review of appropriate documentation from i        the following sources:
i
: 1.          The Managed Maintenance Computer Program's (MMCP) maintenance guidelines for the batteries.
: 2.          The MODS' and MMCP's maintenance history listings for the periods l
listed above.
: 3.          All Maintenance Action Requests (MAR) and Work Orders (WO) l                    generated on the batteries.
: 4.          Preoperational Test Records for the 125 volt DC system.
Upon reviewing all applicable documents, it was determined that the batteries were in Construction's custody from 11/25/81 to 1/27/82.
Except for a few isolated cases during the period 10/29/79 to 5/21/82, an inspection was performed monthly. It was also observed that
 
NOTICE OF DEVIATION ITEM A (445/8605-D-03)
(Continued)
Preoperational Test, ICP-PT-01-04, Rev.1, was performed on 8/15/84 and successfully demonstrated the performance of the 125 volt DC system and since 5/21/82, all weekly battery inspections have been performed.
In conclusion, the data confirms that, even though there is insuffi-  l cient documentation in the PM Program alone to demonstrate the perfor-mance of the subject PM activities, there is adequate evidence to prove that the quality of the equipment has been preserved through other programs, such as corrective maintenance or operation. In other words, the intended activity has been satisfied through other means.
: c. Motor Driven Auxiliary Feedwater Pump 02 (CP1-AFAPMD-02)
The following is in response to the NRC's concerns regarding the PM activities on the Motor Driven Auxiliary Feedwater Pump No. 2 (CPI-AFAPMD-02): "The quarterly rotation was not done from September 27, 1982 until August 18, 1984."
The intent of periodic shaft rotation is to prevent shaft warpage and to ensure that bearing condition is properly maintained during extend-ed periods of inoperation. Therefore, if the pump / motor was operated or rotated for another purpose (i.e., coupling alignment, operation),
the objective of periodic shaft rotation was met.
The evaluation included a review of appropriate documentation from the following sources:
: 1. The Managed Maintenance Computer Program's (MMCP) maintenance guidelines for the pump and its corresponding motor.
l          2. The M0DS and MMCP's maintenance history listings (dating from
;              equipment turnover to April 17,1986) for both the pump and motor.
: 3. All Maintenance Action Requests (MAR) and Work Orders (WO) gener-ated on the pump and motor.
: 4. Preoperational Test Records for the Auxiliary Feedwater System including Nos. ICP-PT-37-01, Rev. 0; ICP-PT-37-01 RT-1, Rev. 0; ICP-PT-37-03, Rev. 0; and ICP-PT-37-03, Rev. 0 (reperformance).
The pump and motor were coupled on February 18, 1982. It should be noted no subsequent work documents required the pump and motor to be uncoupled without recoupling and realigning the equipment. Therefore, all rotations performed subsequent to this date would satisfy both the pump's and motor's rotational requirements.
To justify that the rotational activities were performed, PMs and other related activities were reviewed for the period between Septem-ber, 1982, to August, 1984. The motor's maintenance history indicates that a rotation was performed at frequencies of less than three months. Furthermore, Preoperational Test Records indicate the
 
NOTICE OF DEVIATION ITEM A (445/8605-D-03)
(Continued) motor was operated intermittently throughout this particular period (i.e., pre-op tests were performed from December 4,1982, to May 12, 1983). Retests were performed between June 1 and June 28, 1984.
Other AFW system tests were also made during this period, which required operation of the motor driven pumps and associated equipment.
This data supports the fact that the subject rotation activity was performed in accordance with the requirements and therefore, the quality of the equipment was preserved.
: d. Centrifugal Charging Pump 01 (TBX-CSAPCH-01)
This evaluation was performed in response to the NRC's concerns regarding the PM activities for the centrifugal charging pump (TBX-CSAPCH-01), specifically the absence of shaft rotation documenta-tion for the intervals from 3/25/83 to 2/25/84 and 2/25/84 to 4/3/85.
The intent of periodic shaft rotation is to prevent shaft warpage and to ensure that bearing condition is properly maintained during extended periods of inoperation. Therefore, if the pump / motor was operated or rotated for another purpose (i.e., coupling alignment),
the objective of periodic shaft rotation was met.
This evaluation included a review of appropriate documentation from the following sources:
: 1. The Managed Maintenance Computer Program's (MMCP) maintenance guidelines for the pump / motor.
: 2. The MODS' and MMCP's maintenance history listings for the periods listed above.
3 .- Startup Pre-operational Test PT-49-01 data sheets.
: 4. 0WI 104-7, Auxiliary Operation walkdown records.
Upon reviewing all applicable documents, it was determined that the shaft was rotated at three month intervals or less during the period in question with the exception of the interval from 4/21/83 to 1/18/84. The pump has operated on numerous occasions subsequent to this period with no indication of any resulting equipment degradation.
This is consistent with the fact that quarterly shaft rotation is a very conservative recommendation. Other pump manufacturers have specified periodic rotation frequencies of six months or longer for similar pumps. Therefore, the single nine month interval with no record of shaft rotation is not considered significant and did not degrade the quality or integrity of the equipment.
In conclusion, a period of deficient PM activity (or documentation) was detected upon researching the history of the centrifugal charging pump. Subsequent PM activity and operation indicate that the pump has not been adversely affected.
 
NOTICE OF DEVIATION ITEM A (445/8605-D-03)
(Continued)
Based on the results of the foregoing evaluations, we feel that the quality of the subject equipment has been preserved. Furthermore, we recognize that the incompleteness of the PM program documentation is a weakness in the program as pointed out by the RRI.
: 2. CORRECTIVE ACTION TAKEN A representative selection of pumps and motors will be evaluated in a manner similar to the components listed in this response. If problems are found which would compromise the quality of equipment and would not have been detected by the Surveillance Test Program, a complete review of safety related equipment preventive maintenance will be performed for this period. Deficient or nonconforming conditions discovered during these reviews will be documented in accordance with station procedures.
: 3. ACTION TO PREVENT RECURRENCE Subsequent to the period in question, we have made significant progress toward strengthening our PM program through the implementation of improved documentation. This was accomplished through a revised PM walkdown program which was implemented subsequent to TUGCo QA Audit, TUG-40, in December, 1983, and further enhanced by revisions to procedure MDA-301, Preventive Maintenance Program, in May, 1984, and September, 1985.
Furthermore, as we move closer to operation of CPSES, we will continue to review our PM program to enhance its effectiveness through integration with plant operation activities.
: 4. DATE OF FULL COMPLIANCE Corrective Action - August 31, 1986 Preventive Action - Completed l
l
 
        *
* o                                  NOTICE OF DEVIATION ITEM B (445/8605-D-01) l i
B. In response to two Notices of Violation, the applicant committed to be in compliance with actions stated by specified dates. The first was TXX-4439
:                    dated March 19, 1985, which stated in response to violation 8431-08 that i                  Station Administrative Procedures STA-602 would be revised and issued by June 1, 1985. The second was TXX-4586 dated October 10, 1985, which L                  stated in response to violation 8502-05 that test deficiency report (TDR) i                    4254 was written to document the violation and that clarification of the                          r test data packages would be in full compliance by October 18, 1985.
Clarification of the test data packages included Joint Test Group (JTG) approval of the TDR and filing of the completed TDR in the records center j                    as a supplement to the completed test data packages.
In deviation from the above, as of February 28, 1986, neither action had been completed. The revision to STA-602 was published on March 5, 1986,
  'i approximately 8 months late, and clarification of the test data packages to the extent of JTG approval and filing in the records center was not completed as of the end of this inspection period (445/8605-D-01).
Response to Item B                                                  ,
l            1. REASON FOR DEVIATION I-                  This Deviation involves commitments made in response to two NRC Notices of l                    Violation: 8502-05 and 8431-08. Each commitment will be discussed sepa--
1 rately under the heading of the appropriate violation, followed by common statements of action taken to correct and prevent recurrence of similar 4
deviations.
l                    Discussion of Commitment Concernina Violation 8502-05 i
;                    During an inspection of completed preoperational test data packages, the NRC identified two packages where the STE failed to follow administrative requirements for changing test documents. The response to the Notice of
  !                  Violation dated October 10, 1985, stated that ". . .a Test Deficiency
  !                  Report (TDR No. 4254) has been written to document this violation and it                          ;
j                    supplements these two data packages with clarifying information relative to this violation." The committed data of full compliance was October 18, i                  1985;'however, in February, 1986, the NRC conducted a followup inspection
-                    and found that TDR 4254 was written on October 1,1985, as stated in the i                    response, but did not find the TDR filed in the Records Center with either i                  of the test data packages. Failure to file an approved TDR in the Records
  !                  Center with the' test packages by the committed date or revising the commitment through appropriate channels, constitutes this portion of the
,                    Deviation.
l                    The normal process is such, that if a TDR is initiated against a test data package already filed in the Records Center, the dispositioned TDR is reviewed by the Joint Test Group (JTG) and when approved, that TDR is
;                    filed as a supplement to the test data package of concern.
l                    Realizing that a TDR was required for the response to the violation, then initiating the TDR to provide a documentation path for the response and i
) ,
i I__._.___.___,_____                                        _ _ . _ _ . _ _                      _.__._..__._w
 
F    ,.
      *  *4        ,                      NOTICE OF DEVIATION ITEM B (445/8605-D-01)
(Continued) also knowing that eventually the test data packages would be supplemented by the TDR, all contribute to an incorrect translation of the response corrective action statement by Startup personnel.
Once the TDR was dispositioned and approved by appropriate Startup person-nel in accordance with CP-SAP-16, it was set aside so that the implementa-tion of the preventive action could begin. While ensuring the preventive action was being accomplished and properly documented, timely approval of the TDR by the JTG was overlooked. The TCR was filed as awaiting JTG review.
i              As there was no perceived necessity to require a JTG meeting, none was
!              called until December,1985, and due to JTG membership changes, the TDR j              was not presented at that time. After the December JTG meeting, the next meeting was not required until April, 1986, when TDR 4254 was approved and
;              processed as described above.
Discussion of Commitment Concernina Violation 8431-08
,              Procedure STA-602, Temporary Modifications and Bypassing of Safety Func-
!              tions, was identified in NRC Inspection Report 50-445/8431 as lacking
;              adequate controls for temporary modifications to safety-related equipment.  /
;              The commitment was made in TUGCo's corrective action response, dated March /
i              19, 1985, to revise STA-602 by June 1, 1985. Procedure STA-602 involves l              every Department in CPSES Plant Operations and impact of the proposed l              revision was so extensive that three revision submittals were required prior to issuance on March 5, 1986. Failure to revise the commitment date
,              for revising STA-602 when it could not be met is the cause of this part of the Deviation.
l            2. CORRECTIVE ACTION TAKEN l              A monthly status report of operations related open NRC Inspection items is
;              addressed to the TUGCo Vice President, Nuclear Operations and distributed to responsible department heads for response commitment tracking purposes.
1 When the Deviation was reported to TUGCo Nuclear and Plant Operations
'-              Management in the NRC Resident Reactor Inspectors' monthly exit mooting on March 6,1986, a review of other outstanding commitments was made. It was determined that, with the exception of the noted instances in this
!              Deviation, all response commitments were current. In addition, the following corrective actions were taken:
I              1. TDR 4254 has been approved and the test data packages of cor;.ern have been supplemented by a copy of the TDR.
l              2. STA-602, Revision 1, has been issued containing changes described in
:                    the response commitment.
: 3. The Vice President, Nuclear Operations, stressed in his weekly staff i                    meeting the importance of meeting all response commitment dates or making prior arrangements with the NRC to revise the date.
I i
i
 
f~    ,.
      * ' '
* NOTICE OF DEVIATION (ITEM B (445/8605-D-01)
(Continued)
: 3. ACTION TO PREVENT RECURRENCE As stated in the Corrective Action, the two instances noted in the Notice of Deviation are isolated examples of failure to comply with response commitment dates. To provide additional assurance that all management personnel in the Nuclear Operations Division understand the importance of fulfilling response commitments, a directive to this effect will be issued by the Vice President, Nuclear Operations.
: 4. DATE OF FULL COMPLIANCE Corrective Action has been implemented. Action to prevent recurrence of similar deviations from commitments to the NRC will be complete by July 1, 1986.
s 9
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