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# | {{Adams | ||
| number = ML20135F064 | |||
| issue date = 04/17/1985 | |||
| title = Insp Rept 50-445/85-02 on 850101-0228.Violation Noted: Failure to Follow Administrative Requirements of Startup Administrative Procedure CP-SAP-12, Deviations to Test Instructions/Procedures | |||
| author name = Hunnicutt D, Kelley D, Smith W | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000445 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-445-85-02, 50-445-85-2, NUDOCS 8509170139 | |||
| package number = ML20135F045 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 15 | |||
}} | |||
See also: [[see also::IR 05000445/1985002]] | |||
=Text= | |||
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APPENDIX B | |||
U. S. NUCLEAR REGULATORY COMMISSION | |||
, | |||
REGION IV | |||
NRC Inspection Report: 50-445/85-02 Construction Permit CPPR-126 | |||
Docket: 50-445 Category: A2 | |||
Applicant: Texas Utilities Electric Company (TUEC) | |||
Skyway Tower | |||
400 North Olive Street | |||
Lock Box 81 | |||
Dallas, Texas 75201 | |||
Facility Name: Comanche Peak Steam Electric Station (CPSES) Unit 1 | |||
Inspection At: Glen Rose, Texas | |||
Inspection Conducted: January 1 through February 28, 1985 | |||
Inspectors: > > NZ . / >, | |||
D. L 1(efley', Senior RisiHent _ eactor Inspector | |||
$ll1lW N | |||
Dave ' | |||
i | |||
(SRRI) | |||
* | |||
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W. F. Sm th, Resident Reactor Inspector (RRI) | |||
v/n/n | |||
t Date | |||
Approved: k | |||
D. M. Hunnicutt, Section Chief, Reactor Project | |||
9[/7[Pf | |||
Date | |||
Section B | |||
Inspection Summary | |||
Inspection Conducted: January 1 through February 28, 1985 | |||
(Report 50-445/85-02) | |||
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! PDR ADOCK 05000445 | |||
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1 | |||
- Areas Inspected: Routine, unannounced inspection of (1) preoperational test | |||
4 results evaluation; (2) applicant actions on previous inspection findings; | |||
! | |||
(3) plant, tours; and (4) plant-status. The inspection involved 145 inspector- | |||
: hours by two NRC' inspectors. | |||
. | |||
l Results: Within the 4 areas inspected, one violation was identified (failure. | |||
to follow procedures, paragraph 2). In addition, 8 open items exist in | |||
4 | |||
paragraph 2 pending applicant action, and 3. unresolved items exist in paragraph | |||
2 requiring additional information. | |||
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DETAILS | |||
i | |||
. | |||
1. Persons Contacted | |||
" | |||
k Applicant Personnel | |||
*J. C. Kuykendall, Manager, Nuclear Operations | |||
-*C. H. Welch,-Quality Assurance Supervisor. | |||
' | |||
: *J. C. Smith,-Quhlib Assurance | |||
*R. B. Seidel, Optrations: Superintendent. | |||
*R. E. Camp, Assistant Project General Manager, Unit 1 | |||
, | |||
*R. R. Wistrand, Administration Superintendent | |||
: *R. A. Jones, Manager, Plant Operations- | |||
, | |||
*T. L..Gosdin,' Support ~ Services Superintendent | |||
i *D. W..Braswell, Engineering Superintendent | |||
. | |||
l '*D. E. Deviney, Operations QA Supervisor | |||
j *M. R. Blevins, Maintenance Superintendent | |||
! S.. M. Franks, .Special Project and Technical Support Lead | |||
! | |||
j * Denotes those present at exit interview. | |||
: | |||
; The NRC inspectors also interviewed other applicant employees during this | |||
; inspection period. | |||
? 2. Preoperational Test Results Evaluation | |||
! * | |||
[j The NRC Resident Inspectors conducted an inspection of preoperational test ; | |||
data packages which had been completed, approved by the Joint Test' Group ' | |||
! (JTG) and placed in the station permanent records storage facility. The | |||
2- objectives of this -inspection were to:- ' | |||
o Assure that the applicant is performing an adequate evaluation of | |||
test results, | |||
, | |||
; | |||
o Assure.that all test data are either within previously established | |||
acceptance criteria, or..that deviations are_ properly dispositioned, * | |||
; | |||
i o- Evaluate the adequacy of.the applicant's methods for correcting | |||
i | |||
, | |||
deficiencies and for retesting, if necessary, | |||
. . | |||
o Evaluate the adequacy of. the applicant's administrativeL practices in | |||
, _ maintaining proper testLdiscipline concerning test' execution, test | |||
_ alteration, and test records, and. * | |||
- | |||
: | |||
. 'o- Verify that the applicant'is following his procedures for review, | |||
evaluation, and acceptance of, test results. | |||
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The inspection of each preoperational test package consisted of: | |||
o A review of all test changes to verify that (1) each change was | |||
approved in accordance with pertinent administrative procedures, (2) | |||
the procedure was annotated to identify test changes, (3) the test | |||
change had been completed if it entailed specific actions, and (4) | |||
none of the changes altered the basic objectives of the test. | |||
o A review of all test deficiencies to verify that, (1) each had been | |||
resolved, that the resolution had been accepted by appropriate | |||
management and the JTG, and that retest requirements had been | |||
completed; (2) any system or process changes necessitated by a test | |||
deficiency were properly documented and reviewed. | |||
o A review of the test summary and evaluation to ensure that, (1) the | |||
System Test Engineer (STE) evaluated the test results and signified | |||
that the testing demonstrated that the system met design requirements; | |||
(2) the applicant specifically compared test results with established | |||
acceptance criteria. | |||
o A review of the " official test copy" of the test procedure to verify | |||
that, (1) data sheets had been completed (10 percent minimum sample); | |||
(2) all data were recorded where required and were within acceptance | |||
tolerances (10 percent minimum sample); (3) all test deficiencies | |||
identified were noted and had received appropriate reviews and | |||
evaluations; and (4) individual test steps and data sheets have been | |||
properly signed and dated. | |||
o A review of Quality Assurance involvement to verify that, (1) QA/QC | |||
witness and hold points were observed where called for; | |||
(2) Preoperational Test packages were audited as required by | |||
administrative procedures. | |||
o Verification that the test results have been approved by the | |||
applicant's Joint Test Group and that the review and approval is | |||
documented as required by administrative procedures. | |||
Inspection of the completed preoperational test data packages listed below | |||
revealed minor problems that are generic in nature. These are addressed | |||
below, rather than in the specific comments provided for each package. | |||
Since the preoperational test program for Unit 1 was essentially | |||
- completed, the NRC inspectors considered it appropriate to address these | |||
at this time, so that Unit 2 testing can be improved accordingly: | |||
a. Section 4.8 of Startup Administrative Procedure CP-SAP-21, " Conduct | |||
of Testing," provides instructions for making corrections to test | |||
procedure or data sheet entries, i.e., lining through the entry once, | |||
then dating and signing or initialling the correction. The procedure | |||
- - B | |||
. | |||
. | |||
-5- | |||
directs that data shall not be erased, obliterated, or covered by | |||
" whiteout"'or other means. This is a standard, industry-wide | |||
practice, which the applicant has meticulously adhered to with one | |||
' | |||
general exception. In most test data packages, when the System Test | |||
Engineer (STE) found it necessary to repeat procedure steps, he lined - | |||
through the previous signature, signed and dated the lineout,_and | |||
then signed off the step again when he repeated the step. This is | |||
, the method prescribed by procedure. However, there were instances | |||
when the STE lined through a previous signature without signing and | |||
4 ' dating the lineout, followed by signoff of the step.again when it'was | |||
repeated. If it was assumed that the requirements of.CP-SAP-21, step | |||
4.8 were being followed, then the steps appeared to be missing the | |||
required signoffs, the result being no certification that the steps | |||
had been performed at all. The specifics in each data package where | |||
this problem existed were corrected during final review, in most | |||
cases. Whether or not corrected, th'e NRC inspectors were able'to | |||
find other information in the test data packages such as the | |||
chronological test logs, that substantiated actual reperformance of- | |||
the steps in question. Thus, it is an administrative problem which | |||
complicates-data package review rather than a failure to perform the | |||
required test steps. The generic aspects of this problem were | |||
discussed with the applicant's representatives, with the suggestion | |||
by the RRI that test step signoffs need not be lined through if the | |||
step was in fact performed, because the dates accompanying subsequent | |||
signoffs clearly indicate each time the step:is performed. If a | |||
situation occurs where a step is signed by mistake, the STE could | |||
annotate that the signature is void and explain why in the margin or | |||
in the log. The applicant has committed to take this under | |||
advisement under " lessons learned" for' Unit 2 and will advise the RRI | |||
of action taken at a later date. This is (open) Open Item | |||
445/8502-01. | |||
b. CP-SAP-12, " Deviations to Test Instructions / Procedures," provides the | |||
; requirements and responsibilities for initiation and approval of | |||
minor changes (deviations) to test instructions and procedures. Most | |||
preoperational testing procedures require minor changes just prior | |||
to, or during performance of the test to accommodate last-minute | |||
design changes affecting the test, to correct editorial or typo- | |||
graphical. errors that were missed during the procedure review and | |||
approval process, or to allow alternate testing methods when | |||
unanticipated equipment' problems occur. There were indications of a | |||
trend toward_three problems in the implementation of this procedure: | |||
(1) Section 4.2.4 of CP-SAP-12 requires the author (usually the STE) | |||
of a test procedure deviation (TPD) to describe the reason for | |||
the deviation in the space provided on the TPD form. Examples | |||
exist where technical changes were explained as " typo error." | |||
In other cases the reason just did not leave the reviewer with a | |||
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clear understanding as to why the change was necessary. The | |||
, | |||
specifics have been clarified or corrected on a case basis. The | |||
applicant has indicated prior knowledge of this trend and has | |||
committed to correct it for Unit 2 testing under " lessons learned." | |||
" | |||
Actions taken will be reviewed for adequacy by the NRC and for | |||
tracking purposes shall remain (open) Open Itam 445/8502-02. | |||
(2) CP-SAP-8, " Review, Approval and Revision of Test-Instruction / | |||
, Procedures" and CP-SAP-12 both control the method of changing | |||
test procedures and instructions. Whether the procedure is | |||
revised formally in accordance with CP-SAP-8 or a TPD is utilized | |||
.in accordance with CP-SAP-12, a change must be documented and | |||
, approved in accordance with one of these procedures in order.to | |||
ensure that the objectives of the original test as described in- | |||
the FSAR are kept intact. The RRI observed that during JTG | |||
* | |||
reviews of completed test data packages, deficiencies found which | |||
i | |||
required a change to the procedures after the test was performed ' | |||
j were documented on a' Test Deficiency Report (TDR) and not in | |||
i accordance with CP-SAP-8 or 12. The applicant explained that | |||
revising the procedure in accordance with CP-SAP-8 or 12 after | |||
the test had been completed had no value because the TDR | |||
. documented and explained the change, the reason for the change, | |||
the retesting requirements, completion of corrective actions and | |||
retesting, and in addition, the JTG ultimately approved the | |||
- | |||
action stated on the TDR. While the RRI agreed that this is the | |||
best way to handle and document such changes, CP-SAP-8 and 12 do | |||
; not provide for it, thus administrative provisions must be made | |||
, | |||
to continue this practice. The applicant committed to make the | |||
, | |||
appropriate administrative procedure revisions. This will remain | |||
j (open) Open Item 445/8502-03 until the action is completed.- | |||
, | |||
I (3) Since there is no provision in CP-SAP-12 to limit the extent of | |||
test procedure deviation reports, the complexity and number of | |||
TPDs has increased gradually to the point where full revisions | |||
should be considered. An example of this is described in the | |||
: specific comments for ICP-PT-64-10 below. While it was explained | |||
by the applicant. and is understood by the NRC that the JTG | |||
i ultimately approved the changes during the completed test package | |||
review, the confusion brought about by numerous pen-and-ink | |||
, changes can have a detrimental effect on the quality of the test, | |||
i particularly when there is insufficient space on the page to | |||
enter the changes. The applicant also noted this trend and had | |||
, | |||
indicated that action will be'taken under " lessons learned" for | |||
Unit 2. The NRC will. review this action at a later date and | |||
i evaluate its adequacy. This is (open) Open Item 445/8502-04. | |||
c. In addition to the general commen't's'made above, the NRC inspectors | |||
had the following specific comments and concerns related to the | |||
; completed preoperational test packages inspected: | |||
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(1) ICP-PT-29-02, Revision 1, " Diesel Generator Auxiliary Systems" | |||
There were several instances where the STE failed to initiate | |||
a TPD to authorize minor changes to the procedure, for what | |||
appeared to be unnecessary requirements or editorial errors. For | |||
example, step 7.3.12 was written twice. Instead of deleting the | |||
duplication, the STE did not sign the second step, then six months | |||
later lined through it and added the remark " Void-duplication of | |||
the step on page 15." Data sheets 2, 6, 10 and 14 call for air | |||
compressor shutdown time, t2. The data was not recorded, and | |||
the remark, "no test step to record t2." was entered. These | |||
data points should have been deleted by TPD, because apparently | |||
the shutdown time has no .ignificance when in manual operation. | |||
The data sheets contained a " reviewed by" signature blank which | |||
was not signed. The applicant's representative explained that | |||
the signature blanks should not have been in the procedure. If | |||
not, they should have been deleted by TPD in accordance with | |||
, | |||
CP-SAP-12, not left blank in the completed data package. In | |||
each case during the review of completed preoperational test | |||
data packages, the NRC inspector was shown by the applicant that | |||
the action (or lack thereof) taken by the STE was technically | |||
correct in-so-far as-testing of the system is concerned. However, | |||
this practice is not permitted by administrative procedures. The | |||
above examples constitute a violation of 10 CFR 50, Appendix B, | |||
Criterion V, failure to follow procedure (445/8502-05). | |||
(2) ICP-PT-29-01, RT1, Revision 0, " Diesel Generator Auxiliary | |||
Systems, Retest 1," | |||
No deviations or violations were found. | |||
, | |||
(3) 1CP-PT-29-02, RT1, Revision 0, " Diesel Generator Control Circuit | |||
Functional and Start Test," Retest 1, (Phase I and II). | |||
On data sheet 9, the STE annotated that position 6 of the | |||
temperature selector switch does not exist for stator | |||
temperatures, yet the procedure called for these data. This | |||
requirement should have been deleted by a TPD instead of being | |||
left blank. Again, as above, the STE was technically correct, | |||
but he did not follow the administrative' requirements of | |||
CP-SAP-21 to initiate an approved change. This is another | |||
example of failure to follow procedure addressed under violation | |||
445/8502-05 above. | |||
, | |||
. | |||
. | |||
_ _ . . _ _ _ _ . _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ . _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ . _ _ _ _ _ _ _ _ . . _ _ _ _ | |||
. | |||
- | |||
-8- | |||
(4) ICP-PT-29-03 REDO, Revision 0, " Diesel Generator Load Tests" | |||
(Repeat of test). | |||
TDR 3425 identified a probitm with No. 2 starting air compressor | |||
relief valve lifting below its proper lift pressure. The | |||
corrective action entered on the TDR form required the valve to | |||
be repaired and/or reset. The work document describing comple- | |||
tion of this work stated that the relief valve was not the | |||
problem and that perhaps the pressure gages should be checked. | |||
There was no documentation in the preoperational test data | |||
package showing what action was taken, if any. On October 8, | |||
1984, the TDR was signed off by the STE as " corrective action | |||
completed," with no apparent followup to determine the cause of | |||
the relief valve lifting prematurely. On October 22, 1984, | |||
during performance of ICP-PT-29-03, Retest 1 (below), the relief | |||
valve again lifted prematurely. The STE initiated TDR 3723 to | |||
document the problem. As of the time of this inspection, the | |||
followup actions were not completed. The applicant was requested | |||
to explain why the cause of the relief valve problem was not | |||
resolved prior to starting the second test, and what final action | |||
was taken to solve the problem. The applicant committed to | |||
provide this information. This is (open) Unresolved | |||
Item 445/8502-06. | |||
(5) 1CP-PT-29-03, RT-1, Revision 0, " Diesel Generator Load Test, | |||
Retest 1." | |||
Paragraph 7.1 of this procedure was subjected to many pen-and-ink | |||
(TPD) changes. Incorporation of these changes by the STE rendered this | |||
section of the completed preoperational test package illegible. | |||
As a result, the NRC inspectors could not determine the adequacy | |||
of the test results. The applicant indicated that corrective | |||
actions would be taken including a possible repeat of the test. | |||
This is (open) Unresolved Item 445/8502-07. | |||
(6) ICP-PT-29-03, RT-2, Revision 0, " Diesel Generator Load Test, | |||
Retest 2," | |||
There were no violations or deviations noted during review of | |||
this test. However, it appeared that there may have been some | |||
discontinuity with regard to design drawing updates. The NRC | |||
inspector noted that ICP-PT-29-03, RT-1, did not have any | |||
referenced drawing revision updates prior to starting the test. | |||
This in itself did not indicate a problem, because 1CP-PT-29-03 | |||
REDO which had a similar referenced drawing list, was updated | |||
about two months earlier. However, upon review of ICP-PT-29-03, | |||
RT-2, which also had a similar list of referenced drawings, the | |||
MlFinspector noted that about 40 drawing revisions | |||
_ - _ _ _ _ _ - - _ - - _ _ - _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ | |||
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4 | |||
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4 | |||
-9- | |||
were changed about 10 days before 1CP-PT-29-03, RT-1, was started. | |||
.This raised the question of whether or not ICP-PT 2Y-03, RT-1 | |||
referenced drawings were current during' performance of that test, | |||
or, the current design information was evaluated against the test | |||
procedure. The applicant commented that the sequence of events | |||
were probably misleading, and has committed to provide an | |||
explanation. This is (open) Unresolved Item 445/8502-08. | |||
(7) ICP-PT-29-04, Revision 0, " Diesel Generator Sequencing and | |||
Operational Stability Test" | |||
No violations or deviations'were found. | |||
(8) ICP-PT-29-04, RT-1, Revision 0, " Diesel Generator Sequencing and | |||
-Operational Stability Test, Retest 1." | |||
This' test data package contained 22 TPDs and 9 TDRs. It- | |||
contained many TPD pen-and-ink entries, which rendered the data | |||
package illegible. Consequently the NRC inspectors were unable | |||
to determine whether or not the test objectives were met. The | |||
applicant indicated that corrective actions would be taken | |||
including a possible repeat of the test. This is the second | |||
example of this problem found during NRC inspections of completed | |||
preoperational test data packages. The NRC inspector noted that | |||
the previous example (1CP-PT-29-03, RT-1) was performed by_the | |||
same STE. These two test data packages are the only cases where | |||
the NRC inspectors had been unable to determine the adequacy of | |||
test results due to illegible entries. The applicant acknowl- | |||
- edged this and is taking corrective actions in that regard also. | |||
Thisis(open)UnresolvedItem 445/8502-09. | |||
-(9) ICP-PT-29-05, Revision 0, " Diesel Generator Reliability Test." | |||
No violations or deviations were found. | |||
(10) ICP-PT-29-05, REDO, Revision 0, " Diesel Generator Reliability | |||
Tests" (Repeat of Tcst). | |||
No violations or deviations were found. | |||
' | |||
(11) 1CP-PT-48-02, Revision 0, " Containment Spray System Response | |||
Time and Chemical-Additive Flow Test." | |||
No violations or deviations were found. | |||
(12) ICP-PT-64-05, Revision 1, " Safeguards Test Cabinets / Turbine Trip | |||
Test Cabinets Blocking Circuits Operational Test." | |||
The RRI noted that this preoperational test procedure was utilized | |||
by the STE in a neat and professional manner, and provided an | |||
excellent test data package. No violations or deviations were | |||
found. | |||
. | |||
. | |||
. | |||
-10- | |||
(13) ICP-PT-64-10, Revision 0, " Safeguards Relay Actuation Test." | |||
Prior to the start of this test, the STE executed a 56 page TPD | |||
which had 61 instructions, a few of which required replacing | |||
about 45 of the procedure's 207 pages. On July 2, 1984, this | |||
massive change appeared to have been approved in one day by the | |||
Shift Supervisor and by the Lead Startup Engineer. The TPD | |||
contained inadequate or improper justifications, and in one case | |||
a detailed justification (No. 43) was provided for a change | |||
description that did not exist in the TPD. That is, the change | |||
descriptions skipped from No. 42 to No. 44. The change could | |||
have been made in the procedure, but when the TPD was typed, | |||
instruction number 43 was apparently omitted. A second TPD, | |||
which involved the replacement of 11 more procedure pages, made | |||
additional changes and corrected errors made in the first TPD.- | |||
It became readily apparent upon review of this test data package | |||
that there should be controls over the extent of changes a TPD | |||
can incorporate without full JTG approval. Startup | |||
Administrative Procedures presently have no limits. The | |||
applicant pointed out that although such large changes do not | |||
have the benefit of a JTG review before or during a test, the | |||
JTG has the ultimate opportunity and responsibility to rule on | |||
the acceptability of all changes during the final review of the | |||
completed test data package. The RRI acknowledged this. | |||
However, such extensive changes without a thorough technical | |||
review are subject to error which can affect the quality of | |||
safety-related systems through improper test methods or | |||
equipment manipulation. Since the RRI was unable to determine | |||
whether change number 43 was incorporated, it remains unresolved | |||
as to the acceptability of this completed test data package. | |||
The applicant must demonstrate how this change was incorporated, | |||
assess the impact on the test if not incorporated, and consider | |||
what controls should be implemented to keep the scope of TPDs | |||
down to manageable size and complexity. This is (open) | |||
Unresolved Item 445/8502-10. | |||
No violations or deviations were identified. | |||
(14) 1CP-PT-02-02, "118 VAC RPS Inverters, (REDO)" | |||
This test package was neat and well annotated. The TPDs and TDRs | |||
were well documented and corrective actions were well defined. | |||
No violations or deviations were identified. | |||
(15) 1CP-PT-57-10, " Load Group Assignment." | |||
No violations or deviations were identified, hcwever, two open | |||
items associated with TDRs are listed below. The applicant is | |||
researching records to provide the information to close out | |||
these items. | |||
. | |||
. | |||
. | |||
-11- | |||
o TDR-3676 identified a failure to accomplish the slow | |||
. | |||
transfer of train B bus 12A2 when initiated by the test | |||
procedure. The cause was determined to be binding of the | |||
' | |||
activating bar for device 52b/1EG2. Maintenance Action | |||
Request (MAR) 84-4036 was initiated to adjust the activating | |||
bar. A note on the MAR specified that the retest for the | |||
MAR would be added later. Neither the retest for the MAR | |||
nor the MAR are included in the completed test document. | |||
This is (open) Open Item 445/8502-11. | |||
o TDR-3966 was issued during the completed test package | |||
review. The TDR (item 4) identified 15 drawing changes | |||
pertaining to the referenced drawings in the test package. | |||
The corrective action was to note the changes beside the | |||
referenced drawings. There is no documentation to show | |||
that the thanges were reviewed to ascertain if they | |||
impacted the results of the test. This is (open) Open | |||
Item 445/8502-12. | |||
3. Applicant Action on Previous Inspection Findings | |||
a. (Closed) Unresolved Item 8340-01: Concerns over whether or not the | |||
applicant was going to have sufficient records from which to determine | |||
retests of systems (or subsystems) subjected to extensive electrical | |||
rework af ter preoperational testing was completed. In early 1983 many | |||
electrical cables were determinated, rerouted and/or modified, and , | |||
reterminated. The NRC inspector expressed concern in NRC Inspection | |||
Report 50-445/83-40 that such records will be vital to ensure that | |||
systems are fully retested, and that NRC examination of work packages | |||
will be on going to establish the level of confidence required by the | |||
NRC. Such an examination was subsequently conducted, and no problems | |||
were found that would preclude an adequate retesting program. In the | |||
* | |||
interest of conservatism, the applicant had decided to repeat the | |||
control and interlock sections of 34 preoperational tests and | |||
completely repeat 4 others. This conservative approach coupled with | |||
what appeared to be adequate construction rework records has | |||
established an acceptable level of confidence. This item is | |||
considered closed. | |||
i | |||
b. (Closed) Violation 8340-01: Failure to follow procedures. During | |||
the months of July, August, and September 1983, an estimated 12,000 | |||
documents were transmitted from the Startup group to the applicant's | |||
record center with incorrectly filled out transmittal forms. This | |||
was contrary to the requirements of station administrative procedure | |||
STA-302, " Station Records." In their response to the notice of | |||
violation the applicant indicated that although the requirements of | |||
STA-302 were not being completely followed, each transmittal had the | |||
required " unique identifier," and thus all documents were retrievable. | |||
As such, plant safety was not affected. Permanent corrective action | |||
i | |||
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included retraining and direction of Records Center personnel to | |||
ensure that their activities were in full compliance with STA-302. | |||
Subsequently, in August 1984, an NRC inspection of quality assurance | |||
was conducted (see NRC Inspection Report 50-445/84-31 dated | |||
February 12,1985). The area of records transmittal was addressed and | |||
' | |||
appeared to be under control with no problems noted. This item is' | |||
closed. | |||
c. (Closed) Open Item 8223-01: This item addressed the inability to | |||
attain the required system flow rates during the performance of the | |||
Station Service Water (SSW) preoperational test procedure | |||
1CP-PT-04-01. Corrective actions taken by the applicant included 1 | |||
clearing out partially clogged instrument lines, verification of | |||
installed instrument calibration, removal of possible air bubbles | |||
from installed instruments by filling and venting, revising the test | |||
procedure to obtain additional data points in order to better , | |||
determine the pressure-flow characteristics of the system and its | |||
pumps, and use of back-up test instruments to verify flows. The | |||
repeat performance of ICP-PT-04-01 achieved satisfactory results. | |||
The NRC inspectors witnessed the repeat test in June 1984, which is | |||
documented in NRC Inspection Report 50-445/84-21, dated August 14, | |||
1984. This item is closed, | |||
d. (Closed) Violation 8308-01: Failure to follow procedures. During | |||
Hot Functional Testing conducted in March 1983, the SRRI noted that | |||
ten steps of IP0-001A, Revision 0, " Plant Startup from Cold Shutdown | |||
to Hot Standby" had been changed without using proper administrative | |||
, | |||
controls. The applicant's response indicated that the cause was an | |||
i oversight by control room personnel. Most of the operating procedures | |||
were in draft form, and thus, as a function of procedure check-out, | |||
control room personnel were making pen-and-ink error corrections. | |||
. | |||
' | |||
Personnel using IP0-001A failed to notice that the procedure was | |||
already approved and as such, come under specific administrative , | |||
revision controls. Corrective action taken by the applicant was to | |||
issue CPSES Special Order No. 1-S0-83-005, " Operating Procedures - | |||
" | |||
Use and Changes During Testing" on March 4,1983, in accordance with | |||
STA-207, "Special Order, Night Orders, and Management Memorandums." | |||
The order outlined requirements for the use of operating procedures | |||
during preoperational testing, and cautioned personnel that changes to | |||
1 approved operating procedures are to be made in accordance with | |||
approved administrative controls. The trial-testing and correction of | |||
. | |||
plant operating procedures during the initial testing program is | |||
I encouraged by Regulatory Position C 7 of Regulatory Guide 1.68, which | |||
l is a commitment in the CPSES FSAR. | |||
From the time of this violation in March 1983, through January 1985, | |||
there has been a significant amount of preoperational testing. The | |||
: NRC inspectors have not observed any further problems in the | |||
Operations area of procedure revision control, thus, the applicant's | |||
t preventive actions appear to be adequate. This violation is closed, | |||
i . | |||
I | |||
, | |||
&_ _ _ _ _ _ _ _ ..__ . _ _ _ _ _ _ - . _ _ __ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _ _ ___-________________m__ | |||
. - - | |||
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- | |||
. . | |||
-13- | |||
e. (Closed) Open Item 8308-03: This open item was issued to track the | |||
resolution of comments made by the SRRI while reviewing 12 Initial | |||
Startup (ISU) procedures which he received in draft form. Five of | |||
these procedures yielded specific comments which are documented in NRC | |||
Inspection Report 50-445/83-08 dated April 29, 1983. All comments | |||
provided by the SRRI have been satisfactorily resolved and are | |||
appropriately reflected in the issued procedures approved by the | |||
Station Operation Review Committee (SORC). This item is closed. | |||
' | |||
f. (Closed) Open Item 8221-01: In September 1982, during a routine | |||
inspection, the SRRI noted that station operating logs were lacking | |||
a | |||
consistency in format and detail. This was brought to the attention | |||
of the applicant in NRC Inspection Report 50-445/82-21 dated | |||
October 20, 1982. The applicant took the comment under advisement. | |||
Since that time up to the present, the SRRI and the RRI have been | |||
reviewing the logs as a part of routine plant tours. The attributes | |||
checked have been that the logs accurately reflect plant status and | |||
changes thereto, tests in progress, documentation of problems | |||
encountered during a given shift, and finally, overall compliance with | |||
Operations Department Administrative Procedure 00A-301, " Operating | |||
Logs." The resident inspectors found that the logs generally met the | |||
above criteria. This item is closed. | |||
! | |||
g. (Closed) Open Item 8221-02: During the routine September 1982, " | |||
inspection the SRRI noted an organizational change where the Texas | |||
Utilities Services, Incorporated (TUSI) Engineering and Construction | |||
Manager became the Texas Utilities Generating Company (TUGCO) Startup | |||
Manager. This item was considered open pending the applicant's | |||
review of possible FSAR changes. Since that time, this individual has | |||
become the Assistant Project General Manager, and other organizational | |||
- | |||
changes have taken place. As of the time of this inspection, the | |||
FSAR, through amendment 53 dated July 13, 1984, appears to reflect the | |||
. current organization in this area. This item is closed. | |||
4. Plant Tours | |||
During this reporting period, the SRRI and RRI conducted several inspection | |||
tours of Unit 1. In addition to the general housekeeping activities and | |||
general cleanliness of the facility, specific attention was given to | |||
areas where safety related equipment was installed and where activities ' | |||
were in progress involving safety-related equipment. These areas were | |||
inspected to ensure that: | |||
o Work in progress was being accomplished using approved procedures. | |||
o Special precautions for protection of equipment were implemented, and | |||
additional cleanliness requirements were being adhered to for | |||
maintenance, flushing, and welding activities. | |||
o Installed safety-related equipment and components were being protected | |||
and maintained to prevent damage and deterioration. | |||
, | |||
. _ ._ __ . _ _. __ _ _ , -_ ____ _-_ ___ _. _ . _ _ | |||
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-14- | |||
1 | |||
i | |||
Also during these tours, the SRRI and RRI reviewed the control room and | |||
q shift supervisors' log books. Key items in the log review were: . | |||
o. plant status | |||
; | |||
j o changes in plant status | |||
i | |||
! o tests in progress | |||
* | |||
i | |||
! o; . documentation of problems which arise during operating shifts | |||
t | |||
Overall housekeeping practices in Unit 1 are excellent. There were no | |||
j problems found in the operating logs. | |||
; | |||
! No violations or deviations were found..during the plant tours. | |||
o | |||
4 | |||
i 5. Plant Status as of February 28, 1985 ' . | |||
; , | |||
~ | |||
a. Unit No. 1 is 99% complete with 403 of 422 areas turned over to | |||
; operations custody and 331 of 332 subsystems turned over to operations t | |||
] custody. " Custody" means having immediate authority and responsi- | |||
l bility for operational control of systems or equipment. ' | |||
The applicant has accepted 286 of 332 subsystems for final acceptance. | |||
, | |||
i b. Of the 199 preoperational tests, all are completed on field testing, ! | |||
j and one is pending review and approval of completed data. Seven are ; | |||
i pending NRC completed data inspections. ' | |||
i | |||
i | |||
c. The following NRC inspection findings are open pending applicant i | |||
action and NRC followup inspection to confirm completion for closure. | |||
: The quantitles are based on a manually maintained open items list , | |||
] held by the NRC Resident Inspector's office at CPSES. t | |||
l Last Report This Report ; | |||
i | |||
: | |||
i Violations 10 12 | |||
' | |||
} | |||
Deviations 0 0 I | |||
l | |||
: Open Items 100 97 i | |||
! ! | |||
Unresolved 7 14 . | |||
; | |||
3 | |||
Total 117 123 | |||
Action is underway to complete these items. Closure will be | |||
documented in futurc inspection reports. | |||
! | |||
! L | |||
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: j | |||
; l | |||
L_-_--_________-_-_______--_-____-______--________-_-__---____---____: | |||
. - _ . | |||
. . | |||
-15- | |||
d. Unit No. 2 is 72% complete. The preoperational test program on | |||
systems associated with NRC inspections has not yet started. | |||
6. Exit Interview | |||
An exit interview was conducted on March 1, 1985, with applicant | |||
representatives identified in paragraph 1. During the interview, the SRRI | |||
! | |||
and RRI reviewed the scope of this inspection report and discussed the | |||
inspection findings. The applicant acknowledged the findings. | |||
l | |||
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$ | |||
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.-. .. - .. _. , , . . - . - | |||
}} |
Revision as of 16:50, 1 August 2020
ML20135F064 | |
Person / Time | |
---|---|
Site: | Comanche Peak, 05000101 ![]() |
Issue date: | 04/17/1985 |
From: | Hunnicutt D, Kelley D, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20135F045 | List: |
References | |
50-445-85-02, 50-445-85-2, NUDOCS 8509170139 | |
Download: ML20135F064 (15) | |
See also: IR 05000445/1985002
Text
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
,
REGION IV
NRC Inspection Report: 50-445/85-02 Construction Permit CPPR-126
Docket: 50-445 Category: A2
Applicant: Texas Utilities Electric Company (TUEC)
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES) Unit 1
Inspection At: Glen Rose, Texas
Inspection Conducted: January 1 through February 28, 1985
Inspectors: > > NZ . / >,
D. L 1(efley', Senior RisiHent _ eactor Inspector
$ll1lW N
Dave '
i
(SRRI)
r
W. F. Sm th, Resident Reactor Inspector (RRI)
v/n/n
t Date
Approved: k
D. M. Hunnicutt, Section Chief, Reactor Project
9[/7[Pf
Date
Section B
Inspection Summary
Inspection Conducted: January 1 through February 28, 1985
(Report 50-445/85-02)
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- Areas Inspected: Routine, unannounced inspection of (1) preoperational test
4 results evaluation; (2) applicant actions on previous inspection findings;
!
(3) plant, tours; and (4) plant-status. The inspection involved 145 inspector-
- hours by two NRC' inspectors.
.
l Results: Within the 4 areas inspected, one violation was identified (failure.
to follow procedures, paragraph 2). In addition, 8 open items exist in
4
paragraph 2 pending applicant action, and 3. unresolved items exist in paragraph
2 requiring additional information.
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DETAILS
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1. Persons Contacted
"
k Applicant Personnel
- J. C. Kuykendall, Manager, Nuclear Operations
-*C. H. Welch,-Quality Assurance Supervisor.
'
- *J. C. Smith,-Quhlib Assurance
- R. B. Seidel, Optrations: Superintendent.
- R. E. Camp, Assistant Project General Manager, Unit 1
,
- R. R. Wistrand, Administration Superintendent
- *R. A. Jones, Manager, Plant Operations-
,
- T. L..Gosdin,' Support ~ Services Superintendent
i *D. W..Braswell, Engineering Superintendent
.
l '*D. E. Deviney, Operations QA Supervisor
j *M. R. Blevins, Maintenance Superintendent
! S.. M. Franks, .Special Project and Technical Support Lead
!
j * Denotes those present at exit interview.
- The NRC inspectors also interviewed other applicant employees during this
- inspection period.
? 2. Preoperational Test Results Evaluation
! *
[j The NRC Resident Inspectors conducted an inspection of preoperational test ;
data packages which had been completed, approved by the Joint Test' Group '
! (JTG) and placed in the station permanent records storage facility. The
2- objectives of this -inspection were to:- '
o Assure that the applicant is performing an adequate evaluation of
test results,
,
o Assure.that all test data are either within previously established
acceptance criteria, or..that deviations are_ properly dispositioned, *
i o- Evaluate the adequacy of.the applicant's methods for correcting
i
,
deficiencies and for retesting, if necessary,
. .
o Evaluate the adequacy of. the applicant's administrativeL practices in
, _ maintaining proper testLdiscipline concerning test' execution, test
_ alteration, and test records, and. *
-
. 'o- Verify that the applicant'is following his procedures for review,
evaluation, and acceptance of, test results.
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The inspection of each preoperational test package consisted of:
o A review of all test changes to verify that (1) each change was
approved in accordance with pertinent administrative procedures, (2)
the procedure was annotated to identify test changes, (3) the test
change had been completed if it entailed specific actions, and (4)
none of the changes altered the basic objectives of the test.
o A review of all test deficiencies to verify that, (1) each had been
resolved, that the resolution had been accepted by appropriate
management and the JTG, and that retest requirements had been
completed; (2) any system or process changes necessitated by a test
deficiency were properly documented and reviewed.
o A review of the test summary and evaluation to ensure that, (1) the
System Test Engineer (STE) evaluated the test results and signified
that the testing demonstrated that the system met design requirements;
(2) the applicant specifically compared test results with established
acceptance criteria.
o A review of the " official test copy" of the test procedure to verify
that, (1) data sheets had been completed (10 percent minimum sample);
(2) all data were recorded where required and were within acceptance
tolerances (10 percent minimum sample); (3) all test deficiencies
identified were noted and had received appropriate reviews and
evaluations; and (4) individual test steps and data sheets have been
properly signed and dated.
o A review of Quality Assurance involvement to verify that, (1) QA/QC
witness and hold points were observed where called for;
(2) Preoperational Test packages were audited as required by
administrative procedures.
o Verification that the test results have been approved by the
applicant's Joint Test Group and that the review and approval is
documented as required by administrative procedures.
Inspection of the completed preoperational test data packages listed below
revealed minor problems that are generic in nature. These are addressed
below, rather than in the specific comments provided for each package.
Since the preoperational test program for Unit 1 was essentially
- completed, the NRC inspectors considered it appropriate to address these
at this time, so that Unit 2 testing can be improved accordingly:
a. Section 4.8 of Startup Administrative Procedure CP-SAP-21, " Conduct
of Testing," provides instructions for making corrections to test
procedure or data sheet entries, i.e., lining through the entry once,
then dating and signing or initialling the correction. The procedure
- - B
.
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-5-
directs that data shall not be erased, obliterated, or covered by
" whiteout"'or other means. This is a standard, industry-wide
practice, which the applicant has meticulously adhered to with one
'
general exception. In most test data packages, when the System Test
Engineer (STE) found it necessary to repeat procedure steps, he lined -
through the previous signature, signed and dated the lineout,_and
then signed off the step again when he repeated the step. This is
, the method prescribed by procedure. However, there were instances
when the STE lined through a previous signature without signing and
4 ' dating the lineout, followed by signoff of the step.again when it'was
repeated. If it was assumed that the requirements of.CP-SAP-21, step
4.8 were being followed, then the steps appeared to be missing the
required signoffs, the result being no certification that the steps
had been performed at all. The specifics in each data package where
this problem existed were corrected during final review, in most
cases. Whether or not corrected, th'e NRC inspectors were able'to
find other information in the test data packages such as the
chronological test logs, that substantiated actual reperformance of-
the steps in question. Thus, it is an administrative problem which
complicates-data package review rather than a failure to perform the
required test steps. The generic aspects of this problem were
discussed with the applicant's representatives, with the suggestion
by the RRI that test step signoffs need not be lined through if the
step was in fact performed, because the dates accompanying subsequent
signoffs clearly indicate each time the step:is performed. If a
situation occurs where a step is signed by mistake, the STE could
annotate that the signature is void and explain why in the margin or
in the log. The applicant has committed to take this under
advisement under " lessons learned" for' Unit 2 and will advise the RRI
of action taken at a later date. This is (open) Open Item
445/8502-01.
b. CP-SAP-12, " Deviations to Test Instructions / Procedures," provides the
- requirements and responsibilities for initiation and approval of
minor changes (deviations) to test instructions and procedures. Most
preoperational testing procedures require minor changes just prior
to, or during performance of the test to accommodate last-minute
design changes affecting the test, to correct editorial or typo-
graphical. errors that were missed during the procedure review and
approval process, or to allow alternate testing methods when
unanticipated equipment' problems occur. There were indications of a
trend toward_three problems in the implementation of this procedure:
(1) Section 4.2.4 of CP-SAP-12 requires the author (usually the STE)
of a test procedure deviation (TPD) to describe the reason for
the deviation in the space provided on the TPD form. Examples
exist where technical changes were explained as " typo error."
In other cases the reason just did not leave the reviewer with a
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clear understanding as to why the change was necessary. The
,
specifics have been clarified or corrected on a case basis. The
applicant has indicated prior knowledge of this trend and has
committed to correct it for Unit 2 testing under " lessons learned."
"
Actions taken will be reviewed for adequacy by the NRC and for
tracking purposes shall remain (open) Open Itam 445/8502-02.
(2) CP-SAP-8, " Review, Approval and Revision of Test-Instruction /
, Procedures" and CP-SAP-12 both control the method of changing
test procedures and instructions. Whether the procedure is
revised formally in accordance with CP-SAP-8 or a TPD is utilized
.in accordance with CP-SAP-12, a change must be documented and
, approved in accordance with one of these procedures in order.to
ensure that the objectives of the original test as described in-
the FSAR are kept intact. The RRI observed that during JTG
reviews of completed test data packages, deficiencies found which
i
required a change to the procedures after the test was performed '
j were documented on a' Test Deficiency Report (TDR) and not in
i accordance with CP-SAP-8 or 12. The applicant explained that
revising the procedure in accordance with CP-SAP-8 or 12 after
the test had been completed had no value because the TDR
. documented and explained the change, the reason for the change,
the retesting requirements, completion of corrective actions and
retesting, and in addition, the JTG ultimately approved the
-
action stated on the TDR. While the RRI agreed that this is the
best way to handle and document such changes, CP-SAP-8 and 12 do
- not provide for it, thus administrative provisions must be made
,
to continue this practice. The applicant committed to make the
,
appropriate administrative procedure revisions. This will remain
j (open) Open Item 445/8502-03 until the action is completed.-
,
I (3) Since there is no provision in CP-SAP-12 to limit the extent of
test procedure deviation reports, the complexity and number of
TPDs has increased gradually to the point where full revisions
should be considered. An example of this is described in the
- specific comments for ICP-PT-64-10 below. While it was explained
by the applicant. and is understood by the NRC that the JTG
i ultimately approved the changes during the completed test package
review, the confusion brought about by numerous pen-and-ink
, changes can have a detrimental effect on the quality of the test,
i particularly when there is insufficient space on the page to
enter the changes. The applicant also noted this trend and had
,
indicated that action will be'taken under " lessons learned" for
Unit 2. The NRC will. review this action at a later date and
i evaluate its adequacy. This is (open) Open Item 445/8502-04.
c. In addition to the general commen't's'made above, the NRC inspectors
had the following specific comments and concerns related to the
- completed preoperational test packages inspected
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(1) ICP-PT-29-02, Revision 1, " Diesel Generator Auxiliary Systems"
There were several instances where the STE failed to initiate
a TPD to authorize minor changes to the procedure, for what
appeared to be unnecessary requirements or editorial errors. For
example, step 7.3.12 was written twice. Instead of deleting the
duplication, the STE did not sign the second step, then six months
later lined through it and added the remark " Void-duplication of
the step on page 15." Data sheets 2, 6, 10 and 14 call for air
compressor shutdown time, t2. The data was not recorded, and
the remark, "no test step to record t2." was entered. These
data points should have been deleted by TPD, because apparently
the shutdown time has no .ignificance when in manual operation.
The data sheets contained a " reviewed by" signature blank which
was not signed. The applicant's representative explained that
the signature blanks should not have been in the procedure. If
not, they should have been deleted by TPD in accordance with
,
CP-SAP-12, not left blank in the completed data package. In
each case during the review of completed preoperational test
data packages, the NRC inspector was shown by the applicant that
the action (or lack thereof) taken by the STE was technically
correct in-so-far as-testing of the system is concerned. However,
this practice is not permitted by administrative procedures. The
above examples constitute a violation of 10 CFR 50, Appendix B,
Criterion V, failure to follow procedure (445/8502-05).
(2) ICP-PT-29-01, RT1, Revision 0, " Diesel Generator Auxiliary
Systems, Retest 1,"
No deviations or violations were found.
,
(3) 1CP-PT-29-02, RT1, Revision 0, " Diesel Generator Control Circuit
Functional and Start Test," Retest 1, (Phase I and II).
On data sheet 9, the STE annotated that position 6 of the
temperature selector switch does not exist for stator
temperatures, yet the procedure called for these data. This
requirement should have been deleted by a TPD instead of being
left blank. Again, as above, the STE was technically correct,
but he did not follow the administrative' requirements of
CP-SAP-21 to initiate an approved change. This is another
example of failure to follow procedure addressed under violation
445/8502-05 above.
,
.
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(4) ICP-PT-29-03 REDO, Revision 0, " Diesel Generator Load Tests"
(Repeat of test).
TDR 3425 identified a probitm with No. 2 starting air compressor
relief valve lifting below its proper lift pressure. The
corrective action entered on the TDR form required the valve to
be repaired and/or reset. The work document describing comple-
tion of this work stated that the relief valve was not the
problem and that perhaps the pressure gages should be checked.
There was no documentation in the preoperational test data
package showing what action was taken, if any. On October 8,
1984, the TDR was signed off by the STE as " corrective action
completed," with no apparent followup to determine the cause of
the relief valve lifting prematurely. On October 22, 1984,
during performance of ICP-PT-29-03, Retest 1 (below), the relief
valve again lifted prematurely. The STE initiated TDR 3723 to
document the problem. As of the time of this inspection, the
followup actions were not completed. The applicant was requested
to explain why the cause of the relief valve problem was not
resolved prior to starting the second test, and what final action
was taken to solve the problem. The applicant committed to
provide this information. This is (open) Unresolved
Item 445/8502-06.
(5) 1CP-PT-29-03, RT-1, Revision 0, " Diesel Generator Load Test,
Retest 1."
Paragraph 7.1 of this procedure was subjected to many pen-and-ink
(TPD) changes. Incorporation of these changes by the STE rendered this
section of the completed preoperational test package illegible.
As a result, the NRC inspectors could not determine the adequacy
of the test results. The applicant indicated that corrective
actions would be taken including a possible repeat of the test.
This is (open) Unresolved Item 445/8502-07.
(6) ICP-PT-29-03, RT-2, Revision 0, " Diesel Generator Load Test,
Retest 2,"
There were no violations or deviations noted during review of
this test. However, it appeared that there may have been some
discontinuity with regard to design drawing updates. The NRC
inspector noted that ICP-PT-29-03, RT-1, did not have any
referenced drawing revision updates prior to starting the test.
This in itself did not indicate a problem, because 1CP-PT-29-03
REDO which had a similar referenced drawing list, was updated
about two months earlier. However, upon review of ICP-PT-29-03,
RT-2, which also had a similar list of referenced drawings, the
MlFinspector noted that about 40 drawing revisions
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were changed about 10 days before 1CP-PT-29-03, RT-1, was started.
.This raised the question of whether or not ICP-PT 2Y-03, RT-1
referenced drawings were current during' performance of that test,
or, the current design information was evaluated against the test
procedure. The applicant commented that the sequence of events
were probably misleading, and has committed to provide an
explanation. This is (open) Unresolved Item 445/8502-08.
(7) ICP-PT-29-04, Revision 0, " Diesel Generator Sequencing and
Operational Stability Test"
No violations or deviations'were found.
(8) ICP-PT-29-04, RT-1, Revision 0, " Diesel Generator Sequencing and
-Operational Stability Test, Retest 1."
This' test data package contained 22 TPDs and 9 TDRs. It-
contained many TPD pen-and-ink entries, which rendered the data
package illegible. Consequently the NRC inspectors were unable
to determine whether or not the test objectives were met. The
applicant indicated that corrective actions would be taken
including a possible repeat of the test. This is the second
example of this problem found during NRC inspections of completed
preoperational test data packages. The NRC inspector noted that
the previous example (1CP-PT-29-03, RT-1) was performed by_the
same STE. These two test data packages are the only cases where
the NRC inspectors had been unable to determine the adequacy of
test results due to illegible entries. The applicant acknowl-
- edged this and is taking corrective actions in that regard also.
Thisis(open)UnresolvedItem 445/8502-09.
-(9) ICP-PT-29-05, Revision 0, " Diesel Generator Reliability Test."
No violations or deviations were found.
(10) ICP-PT-29-05, REDO, Revision 0, " Diesel Generator Reliability
Tests" (Repeat of Tcst).
No violations or deviations were found.
'
(11) 1CP-PT-48-02, Revision 0, " Containment Spray System Response
Time and Chemical-Additive Flow Test."
No violations or deviations were found.
(12) ICP-PT-64-05, Revision 1, " Safeguards Test Cabinets / Turbine Trip
Test Cabinets Blocking Circuits Operational Test."
The RRI noted that this preoperational test procedure was utilized
by the STE in a neat and professional manner, and provided an
excellent test data package. No violations or deviations were
found.
.
.
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(13) ICP-PT-64-10, Revision 0, " Safeguards Relay Actuation Test."
Prior to the start of this test, the STE executed a 56 page TPD
which had 61 instructions, a few of which required replacing
about 45 of the procedure's 207 pages. On July 2, 1984, this
massive change appeared to have been approved in one day by the
Shift Supervisor and by the Lead Startup Engineer. The TPD
contained inadequate or improper justifications, and in one case
a detailed justification (No. 43) was provided for a change
description that did not exist in the TPD. That is, the change
descriptions skipped from No. 42 to No. 44. The change could
have been made in the procedure, but when the TPD was typed,
instruction number 43 was apparently omitted. A second TPD,
which involved the replacement of 11 more procedure pages, made
additional changes and corrected errors made in the first TPD.-
It became readily apparent upon review of this test data package
that there should be controls over the extent of changes a TPD
can incorporate without full JTG approval. Startup
Administrative Procedures presently have no limits. The
applicant pointed out that although such large changes do not
have the benefit of a JTG review before or during a test, the
JTG has the ultimate opportunity and responsibility to rule on
the acceptability of all changes during the final review of the
completed test data package. The RRI acknowledged this.
However, such extensive changes without a thorough technical
review are subject to error which can affect the quality of
safety-related systems through improper test methods or
equipment manipulation. Since the RRI was unable to determine
whether change number 43 was incorporated, it remains unresolved
as to the acceptability of this completed test data package.
The applicant must demonstrate how this change was incorporated,
assess the impact on the test if not incorporated, and consider
what controls should be implemented to keep the scope of TPDs
down to manageable size and complexity. This is (open)
Unresolved Item 445/8502-10.
No violations or deviations were identified.
(14) 1CP-PT-02-02, "118 VAC RPS Inverters, (REDO)"
This test package was neat and well annotated. The TPDs and TDRs
were well documented and corrective actions were well defined.
No violations or deviations were identified.
(15) 1CP-PT-57-10, " Load Group Assignment."
No violations or deviations were identified, hcwever, two open
items associated with TDRs are listed below. The applicant is
researching records to provide the information to close out
these items.
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o TDR-3676 identified a failure to accomplish the slow
.
transfer of train B bus 12A2 when initiated by the test
procedure. The cause was determined to be binding of the
'
activating bar for device 52b/1EG2. Maintenance Action
Request (MAR) 84-4036 was initiated to adjust the activating
bar. A note on the MAR specified that the retest for the
MAR would be added later. Neither the retest for the MAR
nor the MAR are included in the completed test document.
This is (open) Open Item 445/8502-11.
o TDR-3966 was issued during the completed test package
review. The TDR (item 4) identified 15 drawing changes
pertaining to the referenced drawings in the test package.
The corrective action was to note the changes beside the
referenced drawings. There is no documentation to show
that the thanges were reviewed to ascertain if they
impacted the results of the test. This is (open) Open
Item 445/8502-12.
3. Applicant Action on Previous Inspection Findings
a. (Closed) Unresolved Item 8340-01: Concerns over whether or not the
applicant was going to have sufficient records from which to determine
retests of systems (or subsystems) subjected to extensive electrical
rework af ter preoperational testing was completed. In early 1983 many
electrical cables were determinated, rerouted and/or modified, and ,
reterminated. The NRC inspector expressed concern in NRC Inspection
Report 50-445/83-40 that such records will be vital to ensure that
systems are fully retested, and that NRC examination of work packages
will be on going to establish the level of confidence required by the
NRC. Such an examination was subsequently conducted, and no problems
were found that would preclude an adequate retesting program. In the
interest of conservatism, the applicant had decided to repeat the
control and interlock sections of 34 preoperational tests and
completely repeat 4 others. This conservative approach coupled with
what appeared to be adequate construction rework records has
established an acceptable level of confidence. This item is
considered closed.
i
b. (Closed) Violation 8340-01: Failure to follow procedures. During
the months of July, August, and September 1983, an estimated 12,000
documents were transmitted from the Startup group to the applicant's
record center with incorrectly filled out transmittal forms. This
was contrary to the requirements of station administrative procedure
STA-302, " Station Records." In their response to the notice of
violation the applicant indicated that although the requirements of
STA-302 were not being completely followed, each transmittal had the
required " unique identifier," and thus all documents were retrievable.
As such, plant safety was not affected. Permanent corrective action
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included retraining and direction of Records Center personnel to
ensure that their activities were in full compliance with STA-302.
Subsequently, in August 1984, an NRC inspection of quality assurance
was conducted (see NRC Inspection Report 50-445/84-31 dated
February 12,1985). The area of records transmittal was addressed and
'
appeared to be under control with no problems noted. This item is'
closed.
c. (Closed) Open Item 8223-01: This item addressed the inability to
attain the required system flow rates during the performance of the
Station Service Water (SSW) preoperational test procedure
1CP-PT-04-01. Corrective actions taken by the applicant included 1
clearing out partially clogged instrument lines, verification of
installed instrument calibration, removal of possible air bubbles
from installed instruments by filling and venting, revising the test
procedure to obtain additional data points in order to better ,
determine the pressure-flow characteristics of the system and its
pumps, and use of back-up test instruments to verify flows. The
repeat performance of ICP-PT-04-01 achieved satisfactory results.
The NRC inspectors witnessed the repeat test in June 1984, which is
documented in NRC Inspection Report 50-445/84-21, dated August 14,
1984. This item is closed,
d. (Closed) Violation 8308-01: Failure to follow procedures. During
Hot Functional Testing conducted in March 1983, the SRRI noted that
ten steps of IP0-001A, Revision 0, " Plant Startup from Cold Shutdown
to Hot Standby" had been changed without using proper administrative
,
controls. The applicant's response indicated that the cause was an
i oversight by control room personnel. Most of the operating procedures
were in draft form, and thus, as a function of procedure check-out,
control room personnel were making pen-and-ink error corrections.
.
'
Personnel using IP0-001A failed to notice that the procedure was
already approved and as such, come under specific administrative ,
revision controls. Corrective action taken by the applicant was to
issue CPSES Special Order No. 1-S0-83-005, " Operating Procedures -
"
Use and Changes During Testing" on March 4,1983, in accordance with
STA-207, "Special Order, Night Orders, and Management Memorandums."
The order outlined requirements for the use of operating procedures
during preoperational testing, and cautioned personnel that changes to
1 approved operating procedures are to be made in accordance with
approved administrative controls. The trial-testing and correction of
.
plant operating procedures during the initial testing program is
I encouraged by Regulatory Position C 7 of Regulatory Guide 1.68, which
l is a commitment in the CPSES FSAR.
From the time of this violation in March 1983, through January 1985,
there has been a significant amount of preoperational testing. The
- NRC inspectors have not observed any further problems in the
Operations area of procedure revision control, thus, the applicant's
t preventive actions appear to be adequate. This violation is closed,
i .
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e. (Closed) Open Item 8308-03: This open item was issued to track the
resolution of comments made by the SRRI while reviewing 12 Initial
Startup (ISU) procedures which he received in draft form. Five of
these procedures yielded specific comments which are documented in NRC
Inspection Report 50-445/83-08 dated April 29, 1983. All comments
provided by the SRRI have been satisfactorily resolved and are
appropriately reflected in the issued procedures approved by the
Station Operation Review Committee (SORC). This item is closed.
'
f. (Closed) Open Item 8221-01: In September 1982, during a routine
inspection, the SRRI noted that station operating logs were lacking
a
consistency in format and detail. This was brought to the attention
of the applicant in NRC Inspection Report 50-445/82-21 dated
October 20, 1982. The applicant took the comment under advisement.
Since that time up to the present, the SRRI and the RRI have been
reviewing the logs as a part of routine plant tours. The attributes
checked have been that the logs accurately reflect plant status and
changes thereto, tests in progress, documentation of problems
encountered during a given shift, and finally, overall compliance with
Operations Department Administrative Procedure 00A-301, " Operating
Logs." The resident inspectors found that the logs generally met the
above criteria. This item is closed.
!
g. (Closed) Open Item 8221-02: During the routine September 1982, "
inspection the SRRI noted an organizational change where the Texas
Utilities Services, Incorporated (TUSI) Engineering and Construction
Manager became the Texas Utilities Generating Company (TUGCO) Startup
Manager. This item was considered open pending the applicant's
review of possible FSAR changes. Since that time, this individual has
become the Assistant Project General Manager, and other organizational
-
changes have taken place. As of the time of this inspection, the
FSAR, through amendment 53 dated July 13, 1984, appears to reflect the
. current organization in this area. This item is closed.
4. Plant Tours
During this reporting period, the SRRI and RRI conducted several inspection
tours of Unit 1. In addition to the general housekeeping activities and
general cleanliness of the facility, specific attention was given to
areas where safety related equipment was installed and where activities '
were in progress involving safety-related equipment. These areas were
inspected to ensure that:
o Work in progress was being accomplished using approved procedures.
o Special precautions for protection of equipment were implemented, and
additional cleanliness requirements were being adhered to for
maintenance, flushing, and welding activities.
o Installed safety-related equipment and components were being protected
and maintained to prevent damage and deterioration.
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Also during these tours, the SRRI and RRI reviewed the control room and
q shift supervisors' log books. Key items in the log review were: .
o. plant status
j o changes in plant status
i
! o tests in progress
i
! o; . documentation of problems which arise during operating shifts
t
Overall housekeeping practices in Unit 1 are excellent. There were no
j problems found in the operating logs.
! No violations or deviations were found..during the plant tours.
o
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i 5. Plant Status as of February 28, 1985 ' .
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a. Unit No. 1 is 99% complete with 403 of 422 areas turned over to
- operations custody and 331 of 332 subsystems turned over to operations t
] custody. " Custody" means having immediate authority and responsi-
l bility for operational control of systems or equipment. '
The applicant has accepted 286 of 332 subsystems for final acceptance.
,
i b. Of the 199 preoperational tests, all are completed on field testing, !
j and one is pending review and approval of completed data. Seven are ;
i pending NRC completed data inspections. '
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c. The following NRC inspection findings are open pending applicant i
action and NRC followup inspection to confirm completion for closure.
- The quantitles are based on a manually maintained open items list ,
] held by the NRC Resident Inspector's office at CPSES. t
l Last Report This Report ;
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i Violations 10 12
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Deviations 0 0 I
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- Open Items 100 97 i
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Unresolved 7 14 .
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Total 117 123
Action is underway to complete these items. Closure will be
documented in futurc inspection reports.
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d. Unit No. 2 is 72% complete. The preoperational test program on
systems associated with NRC inspections has not yet started.
6. Exit Interview
An exit interview was conducted on March 1, 1985, with applicant
representatives identified in paragraph 1. During the interview, the SRRI
!
and RRI reviewed the scope of this inspection report and discussed the
inspection findings. The applicant acknowledged the findings.
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