IR 05000445/1992055

Insp Repts 50-445/92-55 & 50-446/92-55 on 921102-10 & 16-19. No Violations Noted.Major Areas Inspected:Plant Operation & Maint Procedures & Programs

ML20125D855
Person / Time
Site:	Comanche Peak
Issue date:	12/09/1992
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20125D853	List: IR 05000445/1992055 ML20125D851
References
50-445-92-55, 50-446-92-55, NUDOCS 9212160071
Download: ML20125D855 (13)

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APPENDIX U. S. NUCLEt3 REGULATORY COMMISSION

REGION IV

Inspection Report: 50-445/92-55 50-446/92-55 Operating License: NPF-87 Construction Permit: CPPR-127 Licensee: TU Electric Skyway Tower 400 North Olive Street, L. B. 81 Dallas, Texas 75201 Facility Name: Comanche Pet'; Steam Electric Station (CPSES), Units 1 and 2

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Inspection At: CPSES, Glen Rose, Somervell County, Texas inspection Conducted: November 2-10 and November 16-19, 1992 Inspectors: C. E. Johnson, Reactor Inspector Accompanied By: D. Skeen, Events Assessment Branch, Nuclear Reactor Regulation Ma Approved: ,4.h44) /2 /c!/92 Ti F. Stetka, Chief, Maintenance SectTon DRe Division of Reactor S::fety Insoection Summary Areas insoccted (Unit _1.1: No inspection of Unit 1 activities was performe Areas Insoected (Unit 21: Routine, announced inspection of the Unit 2 plant operation and maintenance procedures and program Results:

• Operations procedures have been established and approved for use. -These l

procedures were good and appear to accomplish their intended purpose.

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Final update and revision of approved. procedures had not been completed because of few safety-related systems being turned over to operations.

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• The-established operation procedures program scope, format,.and content l were determined to be in accordance with station administrative procedure '

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• Maintenance procedure scope and content were determine to be goo However, format of maintenance pr dures was not completely implemented in accordance with station administrative procedure * The established operations and maintenance procedures were determined to be technically adequate to accomplish their stated purpose in the control of safety-related operations and maintenance activities, l

• The Unit 2 preventive maintenance program was still in its early stages during this inspection, however, the basic program was already included  !

in the database for those few safety-related systems that were turned l over to operations.

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e Attachment - Personnel contacted and Exit Meeting - - -

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_3 DETAILS 1 PLANT STATUS During this inspection period, Comanche Peak Steam Electric Station (CPSES),

Unit 2, was undergoing the final phase of integrated plant testing required for initial licensing and fuel loa PLANT PROCEDURES INSPECTION (42450,42451)

This inspection was conducted to confirm that plant operation and maintenance procedures are prepared to adequately control operation and maintenance of safety-related systems within applicable regulatory requirement The inspectors verified that the following written administrative procedure controls have been established to assure that procedures will be reviewed, updated, and approved (including 10 CFR Part 50.59 considerations) as required:

o Preparation of procedures including the desired format and content, .

e issuing new and revised procedures, e Controlling temporary changes to procedures, e Control of outdated procedures, and

• Training department awareness of procedure change The inspectors sel.cted a sampling of administrative, operations, and maintenance procedures and verified that review, approval and revision of the procedures have been accomplished in accordance with administrative control In addition, the inspectors verified that the procedure working copy is the latest approved revisio .1 Station Administrative Proceduref (STA) (42450)

The inspectors reviewed selected STAS to determine if they were written, approved, and revised in accordance with regulatory requirements. STAS are the principal implementing procedures for programs specified by the Nuclear Engineering and Operations organizations and those support organizations

.providing service The following procedures were reviewed: 1 e STA-202, Revision 22, " Administrative Control of CPSES Nuclear Engineering and Operations Procedures" e STA-205, Revision 15 " Changes to Jrocedures"

• STA-207, Revision 5, " Guidelines For The Preparation And Review Of Operations Procedures"

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-4-e STA-802, Revision 10, " Acceptance Of Station Systems & Equipment"

• STA-820, P.evision 1, " Reporting And Evaluating Unit Differences" These administrative procedures describe how the plant operating procedures should be written and revised. They also define those personnel responsible for ensur!ng the revisions are reviewed and approved as applicabl In summary, it was found that plant administrative procedures, which were common to both units, were adequat .2 General Plant Procedures (424501 The inspectors reviewed the following integrated plant operating procedures (IP0s):

e IP0-0018, Revision 0, " Plant Heatup From Cold Shutdown To Hot Standby" e IPO-0028, Revision 0, " Plant Startup From Hot Standby" a 'P0-003B, Revision 0, " Power Operations" e 1P0-005B, Revision 0, " Plant Cooldown From Hot Standby To Cold Shutdowr."

These procedures followed the format and content as described in the STA Each procedure was technically adequate to accomplish its stated purpos The inspectors verified that essential prerequisites were included prior to nuclear startup such as:

• A check to insure that instruments are operable and properly set for startup;

• A panel check to verify the position of remotely operated valves, and that proper equipment is operating; and e A valve lineup check of local valve position .

Review of these startup and shutdown IP0s indicated that appropriate limitations wera specified and, during power operation, that reactivity control was specific. Process surveillances were specified for plant systems to insure that the reactor core did not exceed its specified limit Instructions in the IP0s required routine surveillance of systems to detect any abnormal condition In summary, the licensee has operating procedures in place to adequately control safety-related operations within regulatory requirements. However, the inspectors found minor inconsistencies between the Unit 1 and Unit 2 IP0 The minor inconsistencies for Proceduree IP0-003B and -0058 had been corrected. Procedures IP0-001B and -002B had not been revised. A licensee representative stated that Revision 9 to Procedure IP0-002B and Revision 11 to Procedure IP0-001B would address the inconsistencies identified. The licensee

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-5-informed the inspectors that the final reviews will be completed when the systems are turned over to operation .3 System Operatina Procedures (SOP) (42450)

These procedures specify instructions for energizing, filling, venting, draining, startup, shutdown, and change of operating mode of both safety-related and nonsafety-related systems. The inspectors reviewed selected S0Ps to ensure that they were written in the proper format and contained sections describing prerequisites, precautions, limitations, and checklists as prescribed by the licensee's governing Administrative Procedure STA-202, and ANSI N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."

The following procedures were reviewed:

e 50P-201B, Revision 0, " Safety Injection System" e 50P-5088, Revision 1, " Service Air System" e 50P-604B, Revision 2, "480V Switchgear and Motor Control Centers" e SOP-1088, Revision 0, " Reactor Coolant Pump" During the review of the SOPS, the inspectors checked them against the similar Unit 1 procedures and noted some minor differences. Interviews with a licer.see representative revealed that the bulk of the differences were because the Unit 1 S0Ps have been revised as needed during the unit's operating lif The Unit 2 SOPS had not yet been revised because of both time and man)ower constraints. The representative indicated that the Unit 2 SOPS will >e revised as the associated system is tun ed over from the construction department to the operations departmen The procedures required for entrance into Mode 6 will be given the highest priority, with procedures needed for Mode 5 the next highest priority, and so on down the line, with procedures needed for Mode 1 being the lowest priority. The inspectors were given a list of 25 Unit 2 systems that have been turned over to the operations department frau June through October 1992. Most of these systems were nonsafety-related and their associated operating procedures have not been revised. Part of the review process will include comparing the Unit 2 procedures to the Unit 1 procedures for compatibility as prescribed in Procedure ODA-207, " Guidelines for the Preparation and Review of Operations Procedures."

In summary, the Unit 2 SOPS appeared to be adequately written.and technically correct. The S0Ps will need to be updated to incorporate the enhancements made to the Unit 1 procedures as the Unit 2 systems are turned over to the operations department in preparation for Unit 2 initial startup and operatio .4 Operatjons Test Procedures (0PT) [42450';

These procedures prescribe the surveillance testing activities to be performed by the operations department to satisfy Technical Specification requirement Periodic testing of safety-related systems ensure that they will be able to f

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l-6- 1 perform their safety function as needed, lhe inspectors reviewed the l following proctdures to determine proper format and technical content, e OPT-2048, Revision 1, " Safety injection System" e OPT-2158, Revision 0, " Class IE Electrical Systems Operability"

• OPT-217B, Revision 0, " Turbine Overspeed Protection System Test" e OPT-407, Revision 4 "RCS Temperature And Pressure Verification" Review of these procedures included comparing them to the similar Unit 1 OPT Differences were found between the Unit 2 and Unit 1 OPTS. Discussions with the licensee revealed that the bulk of the differences were due to changes in Section XI of the ASME Code, which deals with inservice testing of pumps and valves. The Unit 1 procedures were written to comply with the 1986 edition of the Code, while the Unit 2 procedures comply with Part 6 and 10 of Section XI of the 1989 edition of the ASME Code. The licensee stated that the Unit 1 OPIs will be updated to meet the 1989 ASME Code requirements as they come due for biennial review and that all of them should be revised by the third Unit I refueling outage. Other differences between the two units' OPTS were minor in nature and were due to manpower and time constraints in the Operations Support Departmert. Flaws and typographical errors in the Unit 1 procedures were found during use by the Unit 1 operators and revised accordingly. The licensee stated that when the systems are turned over to the Operations Department, the associated OPTS will be revised to incorporate the enhancements made to the Unit 1 procedures. The inspectors were also informed that in conjunction with the procedure review by operations support, the plant operators actually walk through the procedures to determine their usabilit Any deficiencies noted are included in the updated revisio .5 Conclusion in summary, the inspectors concluded that the licensee has developed adequate operating procedures for Unit 2. There were some inconsistencies identified in the review of these procedures. However, discussions with the licensee and the review of the administrative procedures provided assurance that these differences between the Unit 1 and Unit 2 operating procedures would be i captured. Overall, procedures reviewed were adequate to control safety-related operations within the applicable regulatory requirements.

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3 MAINTENANCE PROCEDURE REVIEW (42451)

l The inspectors selected maintenance procedures from the mechanical, electrical, and instrument.1 tion and controls areas. The inspect;rs also reviewed procedures for control of measuring and test equisent, performing maintenance, and surveillance testing. Prior to this review, the inspectors reviewed the following administrative procedures:

e STA-608, Revision 15, " Control Of Measuring And Test Equipment" e STA-702, Revision ll, " Surveillance Program" l

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• STA-605, Revision ll, " Clearance And Safety Tagging" e MDA-101, Revision 5, " Maintenance Department Organization And Responsibilities" e HDA-202, Revision 1, " Maintenance Department Procedure Users Guide" e HDA-311, Revision 1, " Heter And Relay Calibration Program" e CP-SAP-05, Revision 17, " Safety Tagging Procedure" Procedure STA-605 provides a method for controlling the status and configuration of all systems and components under the control of. the nuclear operations department through the use of component tagging and restoration processes whenever clearances on plant equipment are necessary. Unit 2 clearances for systems not yet turned over-to the operations department are controlled by Startup Administrative Procedure CP-SAP-05. This control will be converted to that established under Procedure STA-605 prior to fuel-loa Procedure STA-605 appeared to be adequate to protect personnel and equipment, and to maintain the operability of plant systems and the integrity of the physical boundaries of pla.t ystem .1 Mechanical Maintenance The inspectors reviewed the following Unit 2 mechanical maintenance procedures and found that procedures were essentially the same as Unit 1 procedure * MSM-50-5713, Revision 1, "Olesel Generator Fuel Oil Tank Cleaning" e HSM-S0-8702, Revision 1, "Hain Steam Safety Valve Setpoint Verification"

e HSM-50-8800, Revision 0, "Section XI Check Valve Disassembly Inspection" e HSH-CO-7309, Revision 1, "RMR Pump Maintenance" e HSM-CO-7304, Revision 1, " Positive Displacement Charging Pump Maintenance" e MSM-CO-7308, Revision 1, " Containment Spray Pump Maintenance" There were some additions, such as the inclusion of Unit 2 Borg-Warner check valves, to the surveillance procedures. There were minor differences identified involving the format of procedure Format changes to the procedures had not been completely implemented in accordance with Procedure STA-202 during this inspection. Format differences will be updated during the biennial review or if a procedure revision is required due to other circumstance In general, the mechanical maintenance procedures were goo . - - -. .. . - . -. . . . - -

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8- Instrumentation and Control (I&C) Procedures These procedures control the plant instrumentation calibration program, maintenance of plant instruments and controls, and measuring and test eculpment. The inspectors reviewed the following procedures for technical adequacy and proper forma * ICA-101, Revision 2, "I&C Work Control"

• ICA-Il4, Revision 2, " Instrument and control Section Procedures" e INC-4014B, Revision 1, " Solid State Protection System Safety Injection Reset Timing Circuit Calibration, Train B"

• INC-4624B, Revision 1, " Channel Calibration Containment Spray Pump 01 Discharge to Recirculation Header Flow, Channel 4772-1"

• INC-6000, Revision 1, " Calibration of Fluke Model 8600A Digital Multimeter"

• INC-6551, Revision 1, " Calibration of Dial, Digital and Vernier Calipers" e INC-78158, Revision 0, " Channel Calibration Reactor Coolant System Loop 1, Cold Leg Wide Range Temperature, Channel 0410F e INC-73268, Revision 0, ' Analog Channel Operational Test and Calibration, Steam Generator Harrow Range Level, Loop 2 Protection Set I, Channel 0529" The inspectors reviewed the I&C procedures index for completeness. It was noted that several procedures were listed with a difference of 4 years between the effective date and the biennial review date. The licensee explained that the effective date is the date the procedure was first issued and does not change until a new revision of the procedure is issued, while the review date is changed after each biennial review to reflect the next biennial review date regardless of whether or not the procedure has been revised. This explanation was consistent with Section 6.7 of Procedure STA-202. While no procedures were found to be out of date, there was no easy way of knowing for certain if a procedure has had its biennial review by looking at either the I&C procedure index or the title page of the procedure. The licensee explained that there is a database that contains procedure histories, including revisions, procedure change notices, and dates of the latest biennial review, which can be called up by a clerk in the administrative services department if neede ,

Several minor inconsi>tencies between Unit I and Unit 2 procedures were identified by the inspectors. These inconsistencies were due to revisions-made to the controlling Administrative Procedure STA-202, after the Unit 1 procedures had already been issued, but prior to the Unit 2 procedures being i

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-9 written. As a result, many enhancements that have been included in the Unit 2 procedures have not yet been incorporated into the Unit 1 ')rocedures. In accordance with the requirements of Procedure STA-202, the Unit 1 procedures will be revised when they receive their biennial review The inspectors concluded that the Unit 2 I&C procedures reviewed were technically adequate to calibrate plant instrumentation, to control the

. measuring and test equipment, and were written in the-proper format in accordance with administrative procedure .3 Electrical Maintenance Procedures (HSE)

These procedures prescribed the repair, replacement, and routine maintenance of plant electrical equipment. The inspectors reviewed the following i procedures for technical adequacy and proper forma * MSE-P2-0861A, Revision 0, " Unit 2, Train A Diesel Generator Protective ,

Relay functional check"

• MSE-P2-5005, Revision 0, " Unit 2 Battery Inter-Cell Connector Resistance Test" e HSE-S2-6302, Revision 0, " Unit 2 480 Volt Air Circuit Breaker Survaillance Test"

• MSE-S2-0402A, Revision 0, " Unit 2, Bus 2EB1 and 2EB3 Overcurrent Surveillance Test"

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The inspectors reviewed the index of Unit 2 electrical maintenance procedures for completeness and found it-to be complete with one exception. The exception was that one of the 36 procedures in the-index was past due for its  :

biennial revie Review of these procedures found them to-be technically adequate to perform the prescribed task, and all but Procedure HSE-P2-5005 were written in the proper format. Preventive Maintenance Procedure HSE-P2-5005 was undergoing review during the inspection and the format will be corrected as part of the revie .4 Preventive Maintenance (PH) and Surveillance Proaram The inspectors' review of the Unit 2 PH program indicated that a basic program was in place in the " plant reliability - an integrated system for maintenance (PR-ISH)" databas The following proceduret core reviewed:

• STA-677, Revision 2, " Preventive Maintenance Program"

• _STA-679, Revision 1, " Predictive Maintenance Program"

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• CP-SAP-25, Revision 6, " Warehouse and Unit 2 Preventive Maintenance i

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o STA-673, Revision 1, " Station Layup Program"

• MSM-P0-3321, Revision 0, " Emergency Diesel Generator 011 Change And l Addition" ,

o MSM-P0-8349. Revision 1, "Limitorque Actuator Periodic Mechanical ,

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inspection" Many of the systems are still controlled under Procedure CP-SAP-25, which gives instructions for PM requirements for both installed and stored i equipment. Once the system and equipment are turned over to operations, then PM requirements fall under Procedure STA-67 As part of the inspection, the inspectors questioned the three maintenance ,

departments about scheduling of required PMs and surveillances. All three departments use the PR-ISM computer program to schedule the required PMs and surveillances. The 1&C department work scheduler gets the information from PR-ISM every Monday morning and checks it against the log of the surveillances scheduled to be performed for the coming year. The scheduler then keeps track of the procedures in the log and if one cannot be worked as- scheduled, it. is rescheduled and tracked to completion. The I&C maiatenance scheduler also maintains an independent computerized database and compares it to the PR-ISM database as a backup system. The electrical maintenance scheduler checks the PR-ISM database at least twice a week and keeps a log that runs 6 montl.s in advance. The mechanical maintenance scheduler also reviews the PR-ISM at least twice a wee The inspectors' determined that the residual heat removal system, which was

.1ust recently turned over to operations, was in the PRI-SM database and being reviewed and compared against the Unit 1 PH pregram by the technical support staff. However, the PM program 1s still in it's early stages because many safetf-related systems have not been turned over from startup to operation As a result, the inspectors were . unable to verify the implementation of the PM progra <

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in conclusion, the inspectors were satisfied that thc operations-and maintenance procedures reviewed were of ger.erally good quality in that they are sufficient to control the operations and maintenance activities of safety-related systems within regulatory reg irements. The existing piant procedures were judged to be fully capable of performing their intended purpos .

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ATTACHMENT 1 PERSONS CONTACTED

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1.1 Ljntisee Personnel

• R. Adams, Instrumentation and Control (l&C) Supervisor C. Borcherding, I&C engineering

• R. Braddy, Assistant Project Engineering Manager

• J. Brau, Supervisor, Operations Support

• R. Carter, Maintenance Engineer R. Cutlip, I&C engineering -

• J. Donahue, Operations Manager

• E. Dyes, Operations Quality Assurance (QA)

R. Green, Maintenance Sup? ort

• J. Hitzfeld, PM Lead, Tecinical Programs

• J. Kelley, Vice President, Nuclear Operations

• D. Kross, Unit 2 Operations

• E. Luengas, Independent Safety Engineering Group (ISEG) Engineer

• J. Hartin, ISEG, Senior Engineer 3

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• McAfee, QA Hanager

• Merca, Liu nsing Engineer

• Moore, Mai enance Engineer

• S, Palmer, Stipulation Manager

• Pendleton, Unit 2 Projects '

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• Phillips, Quality Engineering Supervisor

• Rau, Unit Project Manager

, B. Wallace, Electrical Maintenance Procedure Coordinator

• D. Wilken, Unit 2 Maintenance

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• L. Wojcik, Nuclear and Mechanical Analysis Supervisor

1.2 Citizens Association for Sound Enerny l

• 0. Thero, Consultant

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1.3 NRC Personnel

• Constable, Chief, Plant Support

• Graves, Senior Resident-Inspector, Unit 2

• B. Holian, Project Manager, Unit 2

• J. Whittemore, Reactor Inspector in addition _to the personnel listed below, the inspectors contacted other personnel during this inspection perio * Denotes personnel that attended the exit meeting.

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10 Electric -4-bec to DMB (IE01)

bcc distrib by RIV:

J. L. Milhoan Resident inspector (2)

ORP Section Chief (DRP/B)

Lisa Shea, RH/ALF, MS: MilBB 4503 tilS Systeni DRSS-FIPS RSTS Operator Project Engineer (ORP/B) RIV file DRS Section Chief (DRP/TSS)

D. Skeen, NRR C. Johnso T. Stetka

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2 EXIT MEETING An exit meeting was conducted on November 19 1992. -During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did not identify as proprietary, any information provided to, or reviewed by th inspector ,

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