ML20197E589

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

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: ML20197E539 ML20197E550 ML20197E589
References
50-445-86-05, 50-445-86-5, NUDOCS 8605150285
Download: ML20197E589 (11)

See also: IR 05000445/1986005

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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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PDR ADOCK 05000445 :

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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

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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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