IR 05000445/1987040
| ML20205M971 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/21/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20205M959 | List: |
| References | |
| 50-445-87-40, 50-446-87-31, CPA, OL, NUDOCS 8811030378 | |
| Download: ML20205M971 (43) | |
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DRAFT SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS C0f tANCHE PEAK PROJECT O! VISION -
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SYSTERATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report 50-445/87-40 - 50-446/87-31
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Texas Utilities Electric Company (TV Electric)
Comanche Peak Steam Electric Station i
Units 1 and 2 l
r September 1,1987 - August 31, 1988
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INTRODUCTION The Systematic Assessment of Licensec Performance (SALP)
program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate applicant performance on the basis of this ir. formation.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provice meaningful feedback to the applicant's managenent regarding the NRC's assessment of the facility's performance in each functional area.
A NRC SALP Board, composed of the staff members listed below, met on October 5, 1988, to review the observations and data on performande, and to assess applicant performance in accordance with Chapter NRC-0516, "Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are
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summarized in Section !!! of this report.
(he Board's findings and recommendations were forwarded to the NRC Director, Office of Special Projects, for approval and issuance.
l This report is the NRC's assessment of the applicant's safety performance at Comanche Peak for the period September 1,1987, through August 31, 1988.
The SALP Board for Comanche Peak was composed of:
Chairman: C. I. Grimes, Director, Comanche Peak Project
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Division
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Menhers:
J. L.
,inoan, Director, Division of Reactor Safety, Regicn IV P. F. McKee, Deputy Director, Comanche Peak Project Division J. H. Wilson, Assistant Director for Projects, Coranche Peak Project Division
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J. E. Lyons, Assistant Director for Technical Programs, Comanche Peak Project Division R. F. Warnick, Assistant Director for Inspection Programs, Comanche Peak Project Division
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-3-H. H. Livermore, Lead Senior Inspector for Inspection Programs, Comanche Peak Project Division J. S. Wiebe, Senior Project Inspector for Inspection Programs, Comanche Peak Project Division The following personnel also participated in the SALP-Board meeting.
J. L. Birmingham, Parameter Consultant for Inspection Programs, Comanche Peak Project Division S. P. Burris, Senior Resident Inspector (Operations) for Inspection Programs, comanche Peak Project Division M. K.' Graham, Parameter Consultant for Inspection
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Programs, Comanche Peak.oroject Divisior.
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B. Murray, Chief, Radiological Reactor Programs Branch, Region IV W. D. Richins, Parameter Consultant for Inspection Programs, Comanche Peak Project Division M. F. Runyan, Resident Inspector for Inspection Programs, Comanche Peak Project Division P. Stanish, Parameter Consultant for Inspection Programs, Comanche Peak Project Div:sion J. L. Taylor, Parameter Consultant for Inspection Programs, Comanche Peak Project Division
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A.
Applicant /NRC Activities The previous SALP report was for the period October 1, 1982, through October 31, 1983. The SALP process for the Comanche Peak Steam Electric Station (CPSES) was suspended by letter dated February 20, 1985, because of the considerable attention that was already being devoted by the NRC to evaluating the plant and the company.
By letter dated December 4, 1987, the NRC notified the applicant of the NRC's intent to perform a SALP evaluation in the fall of 1988.
The letter stated that although there was substantial work yet to be done to resolve the adequacy of the design and construction of Comanche Peak, the NRC believed that it was appropriate to repume the SALP process.
This is part of the NRC process of restoring normal regulatory practices at Comanche Peak.
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By letter dated January 22, 1988, the NRC staff approved the Comanche Peak Response Team (CPRT) program plan (Revision 4) and the Corrective Action Program (CAP) as the means by which TV Electric would: (1) identify design and construction deficiencies, (2) develop and implement appropriate corrective and preventive acticr.s and (3) conduct these activities with effective management controls.
In !! arch 1988, the NRC staff issued SSER-14 which evaluated TU Electric's corrective actions related to the design of large and small bore piping and pipe supports.
In July 1988, the staff issued SSERs 15 and 16 which documented the staff's review of the applicant's comprehensive program for resolving technical concerns associated with the design of cable tray and cable tray hangers and with the design of conduit supports, respectively.
SSERs now in preparattun address technical
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disciplines (mechanical, civil, structural, electrical, 180), hVAC supports, equipment qualification, and CPRT collective evaluation.
On June 30, 1988, Citizen's Association for Sound Energy (CASE), Texas Utilities Electric Company (Applicant), and the NRC Staff entered into a Joint Stipulation to withdraw the contentions sponsored by CASE in the operating license and construction permit amendment proceedings.
CASE, the applicant, and the hRC Staff
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Joint resolution and dismissed the proceedings.
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During the present assessment period, the applicant has been engaged primarily in design and construction activities to correct the deficiencies identified by the CPRT program plan and other sources.
In April 1988, the applicant postponed construction and CAP activities on Unit 2 to direct available resources to Unit 1.
At the end of the assessment period, the applicant reported
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construction completion on Unit 1 as 99% and on Unit 2 as 85%.
This assessment is applicable to both Unit 1 and Unit 2.
B.
NRC Direct inspection and Review Activities NRC inspection Activity during this SALP evaluation
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i period included 83 inspections performed with over 20,000 Girect inspection hours expended. The majority of the inspections covered the applicant's CPRT activities and resulting Corrective Action Program. Some of the inspections covered preoperational and related activities in preparation for plant operation.
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The inspections included five team inspections of the Design Validation Program,(a team inspection of the
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Employee Concerns Program SAFETEAli), ano a team inspection of welds using the NRC hondestructive Examination (NDE) van.
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II. SUMARY OF RESULTS A.
Overview
Management's involvement and control are evident by their
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leadership, support, and monitoring of the Comanche Peak
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Review Team activities and Corrective Action Program
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The applicant's approach to the identification and resolution of technical issues from a safety standpoint generally exhibits conservatism.
Their performance in carrying out the Corrective Action Program indicates that upper management is dedicated to safety and to quality.
A weakness has been noted in projecting
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this dedication from upper management down to a few first line supervisors and workers.
This was evidenced by
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-6-continuing problems associated with isolated occurrences of (1) failures to document deficient conditions, (2) inadequate dispositioning of nonconformance reports (NCRs) and deficiency reports (ors), (3) lack of procedure compliance, and (4) procedure inadequacy.
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Applicant management is usually responsive to NRC initiatives and self-identified concerns. Major violations are rare, but repetitive minor violations continue, as discussed above. Many construction deficiencies were identified by TV Electric during the SALP period, several of these were significant. itost of these deficiencies were the result of activities that occurred prior to the SALP period ano were identified by the applicant's self-assessnent programs. TV Electric's nuclear management staff has considerable experience and exper'tise in the nuclear power field, and their attitude toward the NRC's regulations, safety issues, and concerns raised by employees is very good.
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Comanche Peak has historically had a relatively large number of failures on initial operator licensing and operator requalification examinations.
The performance
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in this area is below the national average and does not
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appear to be ieproving. At a management meeting with the HRC on August 30, 1988, the applicant described the results of their preliminary review of the operator training program and attributed the large rumber of failures to an inadequate candidate screening process coupled with a long period of operator inactivity because
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of construction delays. The applicant connitted to improve the screening process and conduct a comprehensive
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review of the CPSES training progran and requalification
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program to effect improvement in this area.
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A sunnary of the applicant's performance in each functional drea is given below.
The previous SALP assessment is not included because TV Electric has made substantial organizational changes since that time and many of the SALP functional areas have changed.
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-7-Performance Functional Category Performance Area (9/1/87 - 8/31/88)
Trend *
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Safety Assessment and Quality Verification
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Engineering and Technical Support
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Soils and Foundativas NR N/A D.
Containment, Major Structures, and Major Supports
none E.
Piping Systems and Supports
none F.
Mechanical Components NR N/A
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Auxiliary Systems
none H.
Electrical Equipment and Cables
none 1.
Instrumentation NR N/A J.
Plant Operation
none K.
Maintenance and Surveillance NR N/A L.
none M.
Securi ty
none N.
Radiological Controls NR N/A Note: NR = Not Rated; N/A = Not Applicable
"Perfonnance Trend: Applicant performance during the last quarter of the assessment perioo is examined to determine if a trend exists that could be used to predict applicant performance during the first few months of the next assessment period.
It is reserved for those instances when it is necessary to focus NRC and applicant attention 6n an area with a declining performance trend, or to acknowledge an improving trend in performanc _ _
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-8-III. CRITERIA Applicant performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no applicant activities or lack of meaningful NRC observations.
Special areas may be added tJ highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
Assurance of quality, including management involvement
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dnd Cpntrol; Approach to the resolution of technical issues from a
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safety standpoint;
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Responsiveness to NRC initiatives;
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Enforcement history;
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Operational and construction events (including response
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to, analyses of, reporting of, and corrective actions for);
Staffing (including management); and
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Effectiveness of training and qualification program.
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However, the NRC is not limited to-these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated accoroing to three performance categories.
The definitions of these performance categories are as follows:
A.
Cateoory 1 Applicant management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Applicant resources are ample
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.g-and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
B.
Category 2 Applicant management attention to and involvement in the performance of nuclear safety or safeguards activities is good.
The applicant has attained a level of performance above that needed to meet regulatory requirements.
Applicant resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels.
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Category 3 Applicant management attention to and involvement in the performance of nuclear safety or safeguards activities
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are not sufficient.
The applicant's performance does not significantly exceed that needed to meet mininal regulatory requirements. Applicant resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.
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IV.
PERFORMANCE ANALYSIS A.
Safety Assessment and Quality Verification
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Analysis This functional area includes all applicant review activities associated with the implementation of applicant safety policies; activities related to l
exemption and relief requests; response to generic
letters and bulletins; and resolution of THI items and other regulatory initiatives.
In addition, it includes applicant activities related to the resolution of safaty issues, 10 CFR 50.55(e)
requirements,10 CFR 21 assessments, safety commtttee ano self-assessment activities, analyses of industry's o;. ational experience, use of feedback from plant QA/QC reviews, and participation in self-improverant programs.
It includes the effectiveness of tre applicant's quality verificatiun function in identifying and correcting substandard or anomalous performance, in identifying
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precursors of potential problems, and in monitoring the overall performance of the plant.
A number of significant changes have occurred in the management of the applicant's QA program.
Currently all of the QA functions and key management personnel are located at the site. This enables appropriate management involvement at the site.
Problems associated with quality, construction, and operation are raised to the highest level of site management.
The Senior Management Overview Committee involves applicant upper management in matters related to quality in a frequent and ongoing manner. This cunmittee is used to direct and improve site work activities. Some programs continue to go through
, iterative changes, which indicate that the applicant's corrective actions may not always be effective.
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The separate startup, construction, and operations QA programs were combined in July 1988 to form one uniform QA program for the site.
The current staff and organizational alignments, together with the necessary policies and procedures, clearly define the key positions in the QA programs. lianagement positions have been staffed with perscenel that have experience levels that meet or exceed requirements.
The depth of nuclear experience of the applicant's staff, including the management positions in all disciplines, is a significant contributor to the effectiseness of the applicant's performance.
An example is the size and level of expertise of the applican:'s audit staff, where technical specialists from othor organizations previously had io be borrowed to conduct some audits.
TV Eleef.ric initiated a new trending progran at the beginni19 of this SALP period.
The new program was initiated to: (1) increase the number of data sources to be trenced, (2) provide for a more timely evaluation of inspection attributes, and (3) provide for increased involvement of trend personnel in determining those areas requiring attention.
The program has resulted in identifying an increased number of items needing correction and identifying those items in a more timely manner.
Also, in the
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area of self-initiated programs-to improve quality, the applicatt implemented the "Quality First" program to involve all site. personnel in a quality ethic, and is encouraging employee participation
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with such rewards as individual recognition and awards.
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The applicant's program.for documenting and correcting identified nonconforming conditions has generally been effective.
However, the NRC has
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identified several problems in the program. For example, nonconforming conditions are documented in
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most cases on either a NCR or & DR. The applicant has had. difficulty in providing procedures that effectively describe when a NCR should be initiated
,pr when a DR is required.
In either case, the nonconforming condition is documented and corrected, but the processing time is increased and effort is duplicated at times. The applicant has revised the
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controlling procedures several times during the SALP period,'each time improving this condition.
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The staff also noted that the backlog of identified problems awaiting correction is remaining constart and is unusually large (about 20,000 total for Unit 1 and Common).
Recognizing this concern, TV Electric is making provisions for the planning, resources, and priorities to reduce this large backlog of items.
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The applicant's policy regarding 50.55(e) deficiency identification, notification,-evaluation, and
reporting is well stated and disseminated in instructions and procedures.
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Theevaluationsof50.55(e)deficienciesare generally good; however, there were several in which
the technical justificatior was inadequate or in which the evaluation of the deficiency and its root rtuse was incomplete.
For example, the poor quality
welds between the restraint brackets ano the Fisher
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control valve actuators.
Eighty-one significant construction deficiencies were reported to the NRC during the appraisal period. This high number resulted from the applicant's extensive corrective action program.
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In this area, seven violations (three concerning documentation control and four involving the applicant's program for identifying and correcting deficient conditions) and one deviation (concerning dCR trending) were identified.
The violations were minor and no trend is evident that would indicate a programmatic breakdown.
TV Electric's policies for handling NRC Bulletins are well stated and disseminated in instructions and procedures that clearly assign responsibilities for addressing the technical issues. Engineering evaluations of NRC Bulletins were generally adequate.
A considerable amount of NRC time and effort was expended to obtain acceptable resolutions
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Jo llRC concerns regarding the adequacy of their responses to NRC Bulletins; those responses occasionally were lacking in thoroughness or depth.
For example, the masonry wall design and Namco limit
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switch bulletins.
However, once this difficulty was identified to management, TV Electric took prompt action to correct the aeficiency.
The applicant's conservative approach is clearly demonstrated in their subsequent reevaluation of their responses to all hRC Bulletins to verify proper response.
TV Electric has exhibited a consistently high level of technical expertise in support of licensing actions.
FSAR changes are well-docun.ented and are accompanied by appropriate technical justification.
An effective licensing staff, including a Bethesda licensing office, has provided timely responses to NRC staff hit 1ctives and requests for information.
The applicant's program for the indoctrination, training, and certificaticn of QC inspectors receives appropriate management attention.
The program has improved inspector understanding of work, adherence to inspection procedures, and knowledge and awareness of changes to these procedures, as evidenced by the small nurrber of nonconforming condition reports resulting from inspector error.
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2.
Performance rating
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The overall assessment of this area indir.ates--
strengths in staffing, training, and management involvenant and control. A slight weakness is indicated in TV Electric's response to, analysis of, and correct 1ve actions for identified deficiencies.
The applicant is consiaerea to be in Performance Category 2 in this area.
3.
Recenaandations a.
NRC Actions The hRC should continue.the inspection effort covering the applicant's implementation of the
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CPRT recommendations and CAP. The NRC should perform an inspection of the applicant's
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self-assessment capability, b.
Applicant Actions The applicant should recsce the backlog of identified problems while continuing to improve the identification, resolution, and correction of deficiencies.
B.
Engineering and Technical Support 1.
Analysis This functional area includes all applicant activities associated with the design of the plant; engineering and technical' support for mairtenance, testing, surveillance, procurement, precperational ano startup testing, and operational activities; and confim. ation management (including maintaining design bases and safety margins).
A major portion of the TV Electric's Corrective Action Program (CAP) has been devoted to a complete design validation of all safety-related systems and components.
The applicant documented the comprehensive design validation in Project Status Reports covering each of the eleven CAP areas.
TV Electric has cstablished effective procedural contruls over the corrective action progra _ _ _ _ _ _ _ _ -
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Procedures are well-stated, controlled, and effective in resolving design deficiencies that might have occurred in the past. There is evidence of prior planning and control of the applicant's program. While some portions of the program were subject to numerous revisions, the revisions usually resulted in improvements to the overall program.
Planning was not always effective as evidenced by the coating removal problems for the service water sys tem.
Similarly, closer management attention in the fire protection area may have reduced the applicant's tendency to change commitments which caused delays in NRC inspections to verify con,pliance. Decision making is usually performed at appropriate levels of management and corporate panagement is regularly involved in site activities and meetings.
As evidenced in the Project Status Reports, a clear
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understanding of the technical issues involved in the corrective action program has been demonstrated.
In most cases the resolution of these technical issues exhibited sound judgement and conservative action.
An example of this is the conservative approach and initiative demonstrated en the "Hilti bolt edge distance" issue where TV Electric took the industry lead in adopting the results of the nanufacturer's latest test data.
In a few other areas such as electrical separation, the applicant has performed special tests to demonstrate that the design meets the applicable criteria.
The applicant has demonstrated a clear understanding of the technical issues involved in the staff's licensing review, while their understanding of inspection issues is only generally apparent.
The applicant did not always display a clear understanding of the specific fire protection requirements, as was reflected in several submittals.
TV Electric's submittals to the staff have been
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technically adequate and generally timely, j
Descriptions of the programs and how they evolved were provided to the staff for review and information.
Each of the Project Status Reports (PSRs), which document the results of a CAP area,
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provided an adequate road map to the resolutions of the technical issues. When other documentation or information was required for the staff to perform a complete review of the issues discussed in the PSRs, TU Electric provided the additional caterial or met with the staff to clarify their submittals.
The applicant's response to staff requests for additional technical information and issues relating to operating license reviews are consistently sound and thorough, However, often in response to compl3x inspection issues, such as the coating removal fron-the service water system, the applicant's staff provides delayed, disjointed, or incomplete information, ho major violations occurred during the assessment period. While procedures for the centrol of engineering activities are in place and generally
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appehr to be well understood, the NRC identified three violations resulting from inadequate engineering verifications and one deviation resulting from an inadequate engineering check.
Another violation resulted from a failure to adhere to an administrative procedure for the control of engineering reviews of design change authorizations (DCAs).
In addition, three other violation s occurred; tuo concerned inadequate nonconfo.mance report dispositions and one concerned an inaiequata procedure.
The corrective action for such deficiencies is usually effective and a progrcnmatic breakdown is not evident.
The appropriate technical expertise is nearly alsays available within the TV Electric staff or their contractors. TV Electric's management and staff have provided adequate oversight of the large number of contractor support staff required to implen.ent i
the CAP.
TV Electric management expert.se is evident and authorities and responsibilities are clearly established. Loth the applicant's and the centractor's staffs are technically competent.
2.
Performance rating
The overall assessment of this area indicates strengths in the approach to the resolution of
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technical issues from a safety standpoint, staffing,
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training and qualifications of personnel, and management involvement and control.
No specific weaknesses were identified.
The applicant is considered to be in Performance Category 2 in this area.
3.
Recommendations a.
NRC Action The NRC should continue the normal inspection efforts applicable to this area as required by the construction, preoperational testing, and
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startup inspection programs.
In addition, inspections and reviews should be conducted to
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assure completion of the design validation l
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process.
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Applicant Actions I
TV Electric should continue special efforts to complete design validation and reconciliation.
Additionally, TV Electric should reemphasize, particularly to their working staff and
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l first-line supervisors, the importance of thorough and complete evaluatior.s of deficiencies and discrepancies, to ensure the i
effectiveness of their corrective action L
efforts.
C.
Soils and Fourdations
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, Analysis This functional area includes all activities pertaining to soils and foundations related to the
construction of the ultimate heat sink and major i
structures.
Specifically, this covers, as
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applicable, subgrade investigatien and preparation, I
fill materials and compaction, embankments, foundations and associated laboratory testing, and related instrumentation and monitoring systens.
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inspection during this report period was primarily limited to documentation review of fill and backfill inspection packages associated with the CPRT.
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The CPRT review of till and backfill documentation was designed to investigate the adequacy of the fill and backfill installation process. The policies anc procedures governing this activity were generally adequately stated and understood. However, one specific example was noted where the programmatic approach for corrective action was lacking in thoroughness and depth. This example involved the dttribute definition, attribute grouping, dnd the statistical validity of the conclusions drawn from this CPRT activity.
This problem was subsequently resolved by additional evaluation and the applicant's issuance of a supplement to the CPRT results report for fill and backfill.
Engineering evaluations are comprehensive and
' technically adequate.
This was evident in the engineering assessment performed by CPRT.
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Responses to NRC questions were generally timely, viable, and thorough. Only minor deficiencies were identified and were not indicative of a programmatic breakdown. No violations were identified.
Technical expertise is clearly evident in the applicant's civil / structural staff.
2.
Performance Rating Because of the limited applicant activities in this area during the assessment period, this area was not rated.
3.
Recommendations a.
NRC Actions None.
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Applicant Actions Non i
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D.
Containment, Major Structures, and Major Steel Supports 1.
Analysis This functional area includes all activities related to the structural concrete and steel used in the containment (including the basemat), major structures, and major steel equipment supports.
It covers all aspects of structural concrete (e.g.,
reinforcing steel', concrete batching, delivery, placement, in-process testing, and curing; liner plate erection and f abrication; and containnent post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam generators,
' pressurizer, polar crane, tanks, heat exchengers, etc.).
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Policies and procedures governing this area are adequately stated and understood and corporate management is usually involved in site activities in an effective manner.
Engineering evaluations were especially commendable in their comprehensiveness and technical adequacy. This was most evident in the engineering essessments performed by the CPRT to resolve ISAP issues.
With respect to the resolution of technical issues, conservatism is routinely exhibited when the potential for safety significance exists.
CPRT and Stone & Webster Engineering Corporation (SWEC)
consistently analyzed problems well beyond the minimum requirements.
For example, exceptional ef forts were noted in th'e' program to identify critical clearances in the plant and in the cleanup of gaps between buildings for seismic concerns.
However, there were some examples where approaches for corrective action were lacking in thoroughness and depth.
Exaniples are: (1)FieldVerification Method (FVH)-075, as initially written, lacked elements needed to effectively (identify ccncrete2) the comparison of attachment spacing violations; the Schmidt Hanner Test to concrete of known strength, which would have greatly enhanced the conclusions of ISAP !!.b was not performed; and (3) deficiencies existed in the walkdown of conduit supports, resulting in a violation for inadequate Hilti bolt err.beoment length, in addition, sorre corrective action resolutions were celayed.
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was most evident in the handling of Corrective Action Request (CAR) 88-22, regarding Hilti bolts welded to a baseplate. The disposition of this issue was delayed approximately 45 days fecm the originally scheduled completion date.
Despite this and other delays in the resolution of issues, the applicant consistently reported significant construction events promptly and completely, including, for example, the Hilti bolt incident described above and the discovery of a concrete void in the Safeguards building.
Technical expertise is clearly evident in the applicant's civil / structural staff. Consultants are appropriately used and not excessively relied upon.
hesponses to NRC questions were generally timely, viable, and thorough. Three minor violations were identified and were not indicative of a programmatic
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breakdown.
2.
Performance Rating The overall assessment of this area indicates strengths in the approach to the resolution of technical issues from a safety standpoint and in staffing.
No specific weaknesses were identified.
The applicant is considered to be in Performance Category 2 in this area.
3.
Recommendations a.
NRC Actions in addition to completion of inspections consistent with the construction inspection program, the NRC should continue inspections of TU Electric activities regarding CAP actions associated with this functional area.
Inspections should include coverage of the Post Construction hardware Validttion Program (PCHVP) and applicant conmitments made to resolve CPRT findings.
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b.
Applicant Actions TU Electric should continue special efforts to complete CAP activities associated with this functional area.
E.
Piping Systems and Supports 1.
Analysis This functional area includes those piping systems described in the licensee's safety analysis report (SAR) that affect the safe operation of the plant.
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It includes those activities and quality checks (e.g., fabrication, installation, configuration, welding, nondestructive examination, and preservice
"inspection) necessary to ensure compliance with the applicable codes and other requirements specified in the safety analysis report, specifications, and
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implementing procedures.
In addition, it includes any nonsafety-related piping or supports that could fail during a seismic event and affect or degrade safety-related systems. Cable trays, cable tray supports, conduit and conduit supports are also included in this area because they are similar activities.
Corporate management is usually involved in site activities in an effective manner as evidenced by meetings with and oversight of engineering contractors.
These meetings address the majority of the work activities and, as a result, work schedules are issued which effectively transmit the planned work and related priorities of the craft involved.
There is evidence of prior planning and assignment of priority.
Procedures for control of activities are stated and defined.
This is exhibited by the detailed procedures covering (1) the multilevel qualification of Train C conduit less than or equal to 2-inch in diameter and (2) the concise Field Verification !!ethoc (FVM) governing the Train A and B conduit as well as the remainder of the Train C conduit.
Both craft and engineering personnel involveo witn cable trays / supports understood the administrative procedures.
This resulted in well cefined work packages.
stated as described in the Policies are adequately (P5Rs) for large bore and Project Status Reports
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a small bore piping and supports which summarize the systematic validation process for safety-related piping and pipe supports. Engineering evaluations are adequate, complete, and well maintained as evidenced by the applicant's response to NRC Bulletin 79-14 and NRC Bulletin 87-02. Corrective action is usually taken but may not be completely effective in correcting the root cause of the problem, as demonstrated by the violation concerning ultrasonic digital thickness measurements which were performed through protective coatings without consideration of the impact of protective coatings on the accuracy of the measurements.
With respect to the resolution of technical issues from a safety standpoint, conservatism is generally evident. This was demonstrated by the comprehensive and effective establishment and implementation of complex programs, procedures and commitments to
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address ASME Code issues involving HRC and ASME jurisdiction requirements and historical problems.
TV Electric's effort also encompassed resolution of significant discrepancies related to ASME requirements which occurred in 1982 during the performance of the Unit 1 Primary System Cold Hydrostatic Test, but were not identified comprehensively until this assessment period.
Design conservatism was amply dernonstrated in the design of cable trays and cable tray supports by the addition of suoports, bracing and side plates to provide an in:reased margin of safety.
Resolutions to technical issues were generally timely with the exception of the applicant's evaluation of weld quality of Fisher control valve seismic arrester brackets.
The applicant nearly always responded to hRC initiatives in a timely manner with acceptable resolutions.
The applicant's initial response to concerns stated in violations and deviations have been acceptable in most cases.
No trajor violations occurred during the assesstrent period. Three violations and three deviations concerning inadequate walkdowns and verifications occurred during the assessment period.
Five other
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violations occurred in this functional area; however, a programmatic breakdown in this area was not apparent. The number of violations and deviations appear to be related to the large number and unusual detail of the walkdowns and verifications.
Key staffing positions are identified and responsibilities are well defined. Qualified and competent staff are available and consultants are appropriately used.
With respect to effectiveness of training and qualification programs, an adequate understanding of work and satisfactory adherence to procedures is
,pemonstrated by the modest number of personnel errors in the work related to cable tray supports and conduit supports.
Inspection of welder qualification, weld filler material control, and
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hydrostatic testing revealed an effective training and qualification program.
Inadequate training was occasionally found to be a root cause of problems.
For example, QC inspectors were not always adequately trained to identify inaccessible inspection attributes with a NCR as required by the Post Construction Hardware Validation Program (PCHYP).
2.
Performance Rating The overall assessment of this area indicates strengths in staffing and responsiveness to NRC initiatives. No specific weaknesses were identified.
The applicant is considered to be in Performance Category 2 in this area.
3.
Recommendation a.
NRC Actions In addition to completion of inspections consistent with the construction inspection program, the NRC should continue inspections of TV Electric activities regarding CAP actions associated with this functional area, l
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Inspections should include coverage of the PCHVP ano applicant commitments made to resolve CPRT findings.
b.
Applicant Actions TU Electric should continue special efforts to complete CAP activities associated with this functional area.
F.
Mechanical Components 1.
Analysis This functional area covers mechanical components;
,such as, pressure vessels, reactor vessel internals, pumps, and valves located in, and attached to, the piping systems described under the preceding
.
functional area. The primary emphasis is on
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discrete components rather than piping or systems.
Almost all mechanical components have been installed for some time. As a result, inspection in this area is limited to that associated with the CAP post construction hardware validation program.
Sufficient inspection was not done in this area to provide a basis for rating.
However, one deviation was noted in this area during an inspection in the quality verification area. Corrective action for the deviation was prompt ano effective.
2.
Performance Rating
!
Eecause of the limited inspection activities in this area during the assessme'nt period, this area was not rated.
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3.
Reco nnendations a.
NRC Actions In adottion to completion of inspections consistent with the construction inspection program, the NRC should continue inspections of TV Electric activities regarding CAP actions associated with this functional area.
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Inspections shculd include coverage of the l
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PCHVP and applicant commitments made to resolve CPRT findings.
b.
Applicant Actions TV Electric should continue special efforts to complete CAP activities assoctried with this functional area.
G.
Auxiliary Systems 1.
Analysis This functional area includes those auxiliary systems in the nuclear f acility that are essential
,for the safe shutdown of the plant or the protection of the health and safety of the public.
It includes systems such as the heating, ventilation and air conditioning; radwaste; fire protection; and fuel
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storage and handling systems.
Fire protection activities not associated with the fire protection system are assessed under the plant operations functional area.
The applicant held meetings to plan and prioritize the HVAC work. These meetings addressed the majority of the HVAC and as a result work schedules were issued which effectively transmitted the planned work and priorities to the involved craft. The
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craf t utilized these schedules and provided feedback to ranagement on whether or not the schedules could be met.
Procedures for the control of activities are well defined. Administrative procedures for control of activities and work packages are complete; however, it is not always clear which drawing is to be used or which revision or DCA is currently applicable.
The applicant is responsive to NRC initiativos as evidenced by the issuance of a stop work order on HVAC work after the hRC notified the applicant that workers were having problems with the work packages and the engineering interface. The applicant implemented corrective action in this area by improving the content of the work packages which made them more concise and manageable, and by
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revising the organization to improve the interface with engineering.
The craft personnel are knowledgeable of the procedures.
Engineering evaluations of HVAC activities are generally adequate and records are generally complete and available. However, minor problems have been cbserved where the documented aases for assumptions were incorrect.
TU Electric's understanding of issues is generally apparent and resolutions are generally timely, such as their actions to change HVAC duct flange types and gasket sealing materials, which resulted in additional margins of safety.
lxpertise is available within TV Electric's staff and Consultants are appropriately used. Experience levels for management and engineering personnel
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results in effective resolution of technical issues.
The training and qualification program contributes to an adequate understanding of work and full adherence to procedures, as indicated by the modest nunter of personnel errors.
No major violations were identified during the assessment period. One minor violation and one deviation were identified; the applicant's corrective action was timely and effective.
2.
Performance Rating The overall assessment of this area indicates strengths in responsiveness to NRC initiatives.
No specific weaknesses were identified.
The applicant is considered to be in Perforr.ance Category 2 in this area.
3.
Recorrendations a.
NRC Actions In addition to completion of inspections consistent with the construction inspection program, the NRC should continue inspections of
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TU Electric activities regarding CAP actions
associated with this functional area.
Inspections should include coverage of the l'
PCHVP and applicant connitments made to resolve i
CPRT findings.
b.
Applicant Actions
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TU Electric should continue special efforts to i
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complete CAP activities associated with this functional area.
H.
Electrical Equipment and Cables r
1.
Analysis This functional area includes important electrical
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components, cables, and associated items used in the electrical systems of the r' ut; such as, motors,
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transformers, batteries, U.m.incy diesel generators, motor control cm.;ers, switchgear, electric racewavs, cable (power, control, and instrument), circuit breakers, relays, and other
interrupting and protective devices.
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l During tne assessment. period prior planning and l
assignment of priorities by the applicant was evidenced by scheduling and performance of Field
l Verification Method (FVM) procedures.
Policies are l
adequately stated and understood, decision making is l
usually at a level that ensures adequate management
review and corporate management is usually involved
!
in site activities in an effective manner as shown i
by the FVM change review process and by management investigation of electrical allegations.
Engineering evaluations are generally adequate and l
corrective actions are usually taken but were not
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always effective in correcting the root cause of
,
problems as indicated by the repetition of these problems.
Evaluations were sometimes incomplete and often not timely.
Examples of these weaknesses are
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inadequately dispositioned NCRs and DCAs which required several iterations to correct a single issue and nucerous changes to electrical specification ES-10 ;i
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In the enforcement area, no major violations were identified and only one minor violation was identified.
Staffing of vacant key positions was usually done in a reasonable time.
However, there has been heavy e
reliance on consultants in this area.
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2.
Performance Rating The overall assessment of this area indicates a weaknets in the resolution of technical issues from a safety standpoint.
No specific strengths were indicated.
The applicant is considered to b, b Performance
,dategory 2 in this area.
3.
Recommendations
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a.
liRC Actions In addition to completion of inspections
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f consistent with the cor,struction inspection i
]
program, the fiRC should continue inspections of TV Electric activities regarding CAP actions
l associated with this functional area.
Inspections should include coverage of the PCHVP and applicant comitments made to resolve
l CPRT fine'ings.
l b
Applicant.t:tions l
TV Electric should continue special efforts to complete CAP activit Hs associated with this i
I functional area.
i a
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Instrumentation i
l 1.
Analysis I
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This functional area covers instrument components and systems that are designed to measure, transmit, l
display, record, and/or control various plant
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variables and conditions.
The reactor protection
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System and the engineered safety features actuation
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system are examples of covered plant systems. Also included are devices such as sensors, transmitters, signal conditioners, controllers and other actuating devices, recorders, alarms, logic devices, instrument air supplies, racks, and panels.
Inspections of the CAP activities in this area found prior planning and assignment of priorities. This was evident in the fairly comprehensive checklist
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utilized for the inspections of the instrument
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tubing walkdowns for FVM-IC-069. Procedures for
control of activities were clearly stated and i
I defined. Control of activities was connunicated through task specific organization charts, flow charts and a responsibility matrix.
<
Engineering evaluations were generally adequate and records were generally complete, well maintained, and available as shown by the evaluations of tubing
,
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spans for flexibility, further, the applicant's design approach was generally conservative as evidenced by the use of absolute values of worst-case combined displacements to evaluate tubing spans.
Ito major violations were identified during the assessment period. One minor administrative procedure violation was identified.
2.
Performance Rating
Secause of the limited inspection activities in this area during the assessment period, this area was not rated.
3.
Econnendations a.
NRC Actions in addition to completion of inspections consistent with the construction inspection program, the NRC should continue inspections of TU Electric activities regarding CAP actions
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associated with this functional area.
i Inspections should include coverage of the PCHVP and applicant commitments made to resulve CpRT findings.
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b.
Applicant Actions TV Electric should continue special ef forts to complete CAP activities associated with this functiond area.
J.
Plant Operation 1.
Ana lysis _
This functional area consists chiefly of the control and execution of activities directly relsted to operating plant systems.
It is intended to include activities such as system startup, shutdown, and lineups.
Thus, it includes activities; such as, monitoring and logging plant conditions, normal
"operations, prestartup test operations, response to transient and off-normal conditions, plant-wide housekeeping, control room professionalism,
.
interface with activities that support operations and operator training.
Management involvement is evident in preplanning and in assignment of priorities for task ccmpletion.
For example, tho startup organization implerrented measures to ensure that prestartup testing progresses smoothl.v. The applicant developed and began exarcising a trip reduction program ouring this assesseent period as a response to NUREG 1475 reconinendations for "near term operating license" plants. The pu pose of the trip reduction program is to ensure that lessons learned during preoperational and startup testing result in the minimization of plant trips after the plant begins operation.
In addition, this program will evaluate plant hardware to determine susceptibility to causing plant trips and appropriate r.odifications will be recommended.
To assure an orderly transition from construction to operation, the applicant has irplemerted an Operational Readiness Review Program.
In some instances, however, management involveirent was not as aggressive as it could have been.
Prior to NRC toentification of problems in the area of operator licensing TV Electric corporate and training managemant did not conduct the necessary
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critical self-assessment to resolve those issues.
Once identified, senior TU Electric management conducted a thorough self-assessment of the training program.
Operational decisions were conservative and made with importance being placed on safety. The operation's staff was almost always responsive to NRC initiatives and concerns.
In those instances where unresponsiveness was noticed, applicant manca,ement took imediate corrective action to resolve the issue. For example, questions regarding the issuance of docurantation fer a discrepancy were nut resolved until the issue was elevated to senior operations management.
' Applicant mananment took aggressive action to resolve plant housekeeping problems identified by the NRC. These issues dealt mainly with the work
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force climbing and stanaing on permanent plant equipment and inadequately protected equipment.
Construction management issued a stop work order and established clear, understandable policies.
This action was successful in improving plant housekeeping and protection of permanent pier.t equipment.
Applicant management is usually responsive to liRC initiatives, for example. the applicant provides a monthly report to corporate management which trends current NRC and thPO recomended performance indicators.
In addition, operation's management has been responsive to NRC requests for inforr'ation and responsive to NRC identified deficiencies.
The enforcement history for this functional area has been good. Two significant violations concerning testing issues (cold hydrostatic test and prerequisite testing for the auxiliary feedwater pump motors) were identified during the assessment period but the tests had occurred more than four years prior to the start of the assessment period.
These violations are not considered representathe of current applicant performance.
An enforcement conference was held concerning the second violation to assure that adequate corrective action was taken to prevent recurrence. A deviation was also issued
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as a result of inadequate post work testing procedures; the corrective actions for the deviation were adequate to prevent recurrence.
The applicant's performance with respect to the identification operational deficiencies and response to operational events and deficiencies is marginally acceptable. The applicant continued to experience problems identifying and documenting problems associated with their tagging and clearance procedures.
The repetitive deficiencies indicate that the root cause was not adequately addressed or that correc-tive actions were not effective in preventing recurrence.
For example, multiple flooding events and improper valve lineups occurred during system pperations and testing.
Upper level operation's management is aware of this problem and is taking action to correct it; they have initiated an in-ternal operation's review program to document events
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on Plant Incident Reports. These reports of all plant problems are reviewed by operations management.
The number of operators and shift supervisors exceeds the requirements for single unit operation and is adequate for two unit operations.
Upper and mid-level operations managers are experienced in the operation of commercial nuclear power plants and exceed regulatory requirements and commitments.
Although the licensed cperators and senior operators generally lack comercial power experience, management is aware of this problem and has implemented a program to obtain operating experience for the operators at sinilar facilities.
Key operations positions were filled in a timely manner.
Although the applicant's formal training program for licensed operators and senior operators has not been effective in developing candidates who can consistently pass the NRC licensing examination, as previously oiscussed, training staff positions are filled with individuals possessing the various expertises and skills reoutred in an effective l
training organization. The training staff routinely displays a keen interest in training and they realize their important role in safe plant l
operation.
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Operations activities within the centrol room are consistently conducted in a professional manner.
On-shift personnel and their positions are clearly identified by name tags.
Preshift briefings and turnovers are cotiducted in a' controlled and professional manner. Shift supervision regularly
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ccnducts routine tours of plant areas under their control. Access to the at-the-controls area is clearly marked and well controlled at all times.
The applicant has installed a center control roca console providing a raised area from which supervision can control all of.the activities in each control board area.
In addition, the console physically separates Unit 1 and ll nit 2 control board areas.
This reduces the possibility of distraction i
of the reactor operators. Control room human
' factors modifications continued throughout the
'
assessment period.
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2.
Performance Rating The overall assessment of this area indicates strengths in staffing and in response to NRC
initiatives. Weaknesses were indicated in response to, analysis of, and corrective acticos for events; and in operator training.
I The applicant is considered to be a Performance Category 2 in this erca.
3.
Recommendations a.
hRC Actions The NRC should continue inspections consistent with the Preoperational Testing (2513) and Startup Testing (2514) inspection programs.
The NRC should identity those operational activities Which requite Close examination during the operational readiness team inspection.
b.
Applicant Actions The applicant should continue to improve their identification and response to operational events and deficitncies and to direct attention
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tuward readiness to receive an operating license. The applicant should also continue their efforts to improve the licensed operator training and requalification programs.
K.
Maintenance and, Surveillance 1.
Analysis This functional area includes all activities associated with either diagnostic, predictive, preventive or correctivo maintenance of plant structures, systems, and components; procurement, control, and storage of corponents, including qualification controls; installation of plant nodifications; and maintenance of the plant physical iondition.
It includes conduct of all surveillance (diagnostic) testing activities as well as all inservice inspection and testing activities.
.
Examples of activities included are instrument calibrations; equipment operability tests; post-maintenance, post-nodification, and post-outage testing; containment leak rate tests; water chemistry controls; special tests; inservice inspection and performance tests of puxps and valves; and all other inservice inspection activities. Also included in this assessment are activities associated with lay up of systems which are not in use.
The maintenance organization appears to be adequately trained, managed, and staffeo.
In all Cdhes, managerent takes-an active role in planning and prioritizing work assignments. Management is also heavily involved in the procedure generation and training processes.
Procedures were available and being used effectively and work requests were properly issued and safe working practices were adhered to.
Two violations were identified. One was in the area of deficiency identificatien and corrective action.
Several examples were included in the violation and sintiar violations were noted in other functional areas. One example identified in the violation ir.volved the root cause r.ot being determined and
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corrected following the installation of an incorrect gasket. The other violation concerned an inadequate installation procedure for steam generator manway gaskets.
Corrective action is being taken; however, the NRC continues to be concerned with the applicant's use of the docurent change authorization (OCA) system for the identification of nonconforming conditions.
The corrective maintenance work order backlog at the end of this assessment period was approximately 1600 total items which included mechanical, 1&C, electrical,andallpreventativemaintenance(pM)
items.
The applicant is presently generating about 500 new work orders per month and completing approximately 1000 outstanding work orders in the
'some time period. Assuming there is no increase in work order generation, the applicent should be able to work down their work order backlog to 100-150
.
items in about 3-5 months.
The appl' cant had planned to irplerant a rework trending program during the latter part of this assessment period; however, they are still converting the raw data to a useful form before deciding on a course of action.
TV Electric has a dedicated maintenance training
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f acili ty. The f acility has actual equipment, purchased from cancelled nuclear plants, that is used to conduct hands on training.
2.
Perforrance Rating Decause of the limited inspection activities in this area curing the assessment per iod, this area was not rated.
3.
Recorrrendations a.
NRC Actions The NRC should continue inspections consistert with the Preoperational Testing (2513) and Startup Testing (2514) inspection program.
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b.
Applicant Actions The applicant should continue to direct attentiun toward readiness to receive an operating license.
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Analysis This functional area includes activities related to the establishment and implementation of the emergency plan and implementing procedures; such as, onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations;
' applicant's performance during exercises and actual events that test emergency plans; administration ano implementation of the plan (both during drills and
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actual eients); notification; radiological exposure control; recovery; protective actions; and interactions with onsite and offsite emergency response organizations during exercises and actual events.
.
One emergency preparedness inspection was conducted by the HRC during the assessment period.
No exercises were conducted and no violations or deviations were identified in this period.
Although the inspectiun activities during the assessment period were extremely limited, and the applicant's emergency response facilities are undergoing substantial changes, the staff cencluded that sufficient information exists to draw important conclusions about TV Electric's performance in this area.
It should be noted, hcwever, that considerable work remains to ba completed which will require continued management attention.
The applicant has demonstrated a strong commitment to provide management support to the development of a cuality emergency preparedness program.
This is shown, for example, in the academic background and experience of the emergency preparedness staff, and in the amount of resources applied in various emergency preparedness activities; such as, training program improvetents, quality assurance audits, and state-of-the-art facilities, and equipment and supplics. TU Electric's pursuit of excellence is
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clearly demonstrated in their efforts to relocate the Operations Support Center so it can provide better operations support and enhance logistics during actual events.
In addition, the applicant has implemented an aggressive and comprehensive
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audit program to identify potential problem areas.
As a consequence of these audit programs, the training program is presently undergoing a comprehensive review and revision. The applicant interaction with offsite agencies appeared to Le regular and adequate.
Although emergency response facilities appear to be basically adequate, they are undergoing some modifications for further improvement. The TechnicalSupportCenter(TSC)forexample,is Undergoing an extensive rebuilding and reconstruction of the ventilation systems.
As a consequence, equipment related to emergency response
.
in the TSC was temporarily unusable and could not be inspected for its operability.
In addition, the Operational Support Center is scheduled to be moved to a location adjacent to the health physics access control area, and the Emergency Operations Center is i
undergoing a design modification to provide back-up power supplies.
The staffing levels for the emergency preparedness
,
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program is adequate; however, because of changes to training lesson plans and revisions to emergency
,
implementing procedures, only 40 percent of
'
emergency response training has been completed.
The applicant is presently developing revised emergency preparedness impleinentation procedures that will be l
used in training.
2.
Performance Rating The overall assessment of this area irdicates strengths in the resolution of technical issues from a safety stanopeint, in staffing, and in management involvenent and control.
No specific weaknesses
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were indicated.
The applicant is considered to be in Performance Category 2 in this area.
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3.
Board Recomendations l
6.
hRC Actions The f RC should continue inspections consistent f
with the Preoperational Testing (2513) and Startup Testing (2514) inspection programs with
!'
emphasis on evaluating the applicant's
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preoperations and readiness to receive an operating license.
b.
Applicant Actions Considerable work remains to be conducted to
reach an adequate level of energency response i
readiness.
The applicant should continue the present level of management attention regarding
,'
the schedule for completing the implementation of the emergency preparedness program.
.
H.
Security 1.
Analysis
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This functional area includes all activities that ensure the security of the plant including all p
aspects of access control, security cf.ecks, safeguards, and fitness-for-duty activities and controls.
The area was inspected three tires by security inspectors. The inspection activities involved a review of the proposed security program necessary
,
for obtaining an operating license and the fuel storage security requirements identified in the
,.
Special Nuclear Naterials license.
No violations or
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deviations were identifico.
lianagement demonstrates a strong comitrent to the establishment of a high quality security prograr.i.
Management has cccriitted the necessary resources to
[
ensure that proper fa:ilities and equipment are
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utilized and that an adequate nurber of personnel are available to implement the security program.
Most of the systems and equipment originally
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scheduled for installation have been removed and r
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replaced by updated state-of-the-art systems.
The
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applicant has assembled the nucleus for a competent security organization which includes personnel with a variety of nuclear power plant security backgrounds. The security organization has ccconstrated a good understanding of security technology and continuously evaluates new advances in the security area in order to enhance their program. Most of the supervisory positions within the security organization have been filled with well qualified personnel.
The applicant has established a gcod internal audit / assessment program to identify potential problem areas and program enhancements.
The applicant has established procedures for the evaluation, resolution, and reporting of security events.
Security problems other utilities have encountered in obtaining an operating license have
'been reviewed in order to avoid similar problems at Comanche Peak.
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The majority of the systems and equipment associated with the security program have been installed, but preoperatioral testing and verification remains to be completed. The applicant has determined the number of security guards needed to implement an adequate program, but hiring has not rcen completed to fill these positions.
The applicant has established a comprehensive training ard qualification program that security personnel are scheduled to complete before being certified as qualified guards.
A draft physical security plan and associated implementing procedures have been completed.
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2.
Performance Rating
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The overall assessment of this area indicates strengths in management involvement and control, in resolution of technical issues from a safety standpoint, in responsiveness to NRC initiatives, and in training and qualification effectiveness, i;o specific weaknesses were identified.
The applicant is considered to be in Performance Category 1 in this area.
The SALP boaro r.otes, however, that the applicant's security plan is not yet required to be in;plemente.
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3.
Board Recommendations a.
NRC Actions The NRC should continue its inspection activities related to implementation of the applicant's security program, b.
Applicant Actions Management should continue to provide strong support for the security program. Management should continue to monitor progress made in the testing and verification of security systems, hiring of security guards, and the training and qualificatiens of the guard force to ensure that these tasks are con;pleted in a timely
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manner.
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H.
Radiological Controls 1.
Analysis This functional area consists of activities directly related to radiological controls including occupational radiation safety (e.g., occupational radiation protection, radioactive materials and contamination controls, radiation field control, radiological surveys and monitoring, and as low as is reasonable achievable programs), radicactive waste r.dnagement (i.e., processing and onsite storage of gaseous, liquid, and solid waste),
radiological effluent control and monitoring (including gaseous and liquid effluents, offsite dose calculations, radiological environmental ronitoring, and confirmatory reasurements), and transportation of radioactive caterials (e.g.,
procurement of packages, preparation fcr shipment, selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, and point-of-origin safeguards activities.)
Only the applicant's radiological environmental monitoring (REM) program was inspected during the assessment period.
The applicant's chemistry /environrental section (CES) administers
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the program and performs the environmental sampling.
The radiological analyses required are performed by an offsite contractor.
The REM surveillance is being conducted in accordance With station procedures and draft technical specification requirements. The applicant has establishec procedures for the collection and processing of environmental samples. A training and
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qualification program has been initiated for CES personnel.
The CES was fully staf fed at the time of the inspection in accordance with planned plant organizational levels. During the assessment period, kne applicant has increased the staff by ebout 25 percent.
The applicant has prepared and submitted its annual
.
radiological environmental monitoring reports in accordanee with draft technical specification requirements. The land use census was conducted as required during the assessment period.
The applicant has established and maintained radiological environmental sampling stations as described in the draft offsite dose calculation manual and draft technical specifications. All radiological environmental samples have been collected and analyzed as required, ho problems were identified regarding assurance of quality, i
resolution of technical issues, responsiveness to hRC initiatives, and enforcement.
The NRC identified an area of concern regarding the applicant's ability to maintain adequate control of both radiographic and radiological barriers. A review of applicant records revealed at least five
,
instances where personnel violated radiation barriers since September 1987, i;one of the incidents resulted in any significant exposure to
those individuals involved. Subsequently, late in the assessment period, the applicant identified l
another case in which an incividual violated l
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radiation barrier requirements specified in the I
Special Nuclear Material license regarding the new fuel storage area.
The hRC issued a violation concerning this event.
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2.
Perforrance Rating There was not an adequate inspection basis to assign a rating.
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3.
Board Recommendations a.
NRC Actions The hRC should continue inspections consistent with the Preoperational Testing (2513) and Startup Testing (2514) inspection programs with erphasis on evaluating the applicant's
'
preoperations and readiness to receive an l
operating license.
6.
Applicant Actions
,
'
,
'
The applicant should continue its current l
.
support and emphasis on the radiological controls area.
!
0.
Supporting Data and Sunnaries A.
Enforcer.ent Activity No civii penalties were proposed or issued during the assessment period. On December 8, 1987, an enforcement l
i conference was held to discuss three violations regarding a reversed cooling fan on the Unit 1 auxiliary
,
'
teedwater (AFW) pump motors.
The enforcement conference
,
was held because the violations warranted n.anagement j
l l
attention. No civil penalty was issued.
l
{
Possible escalated enforcefnent action which has the
'
potential to result in a civil penalty was pending at the close of the assessment period. This potential escalated enforcement action concerned the lack of effective i
quality assurance controls when removing the epoxy lining
[
I from the inside of the service water system piping.
j t
!
Table I provides a tabulation of NRC enforcenent activity i
during the assessment period for each functional area.
B.
Confirmation of Action Letters l
None were issued during the appraisal period.
i
!
.
c
!
-
-
-
-
- -. -
-
-.
-
-
- -. -
-
.
.
- - - -
-
- -
-
-
-
-
- -
_ _ _ _ _
__
_
___
_ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
C d
.
- 42 -
C.
Allegations At the begint !ng of the appraisal period there were 57 open allegations.
During the assessment pericd 48 allegations were civ:ed and 20 allegations were received.
At the conclusion of tnc appraisal period, 29 allegations remained open.
The applicant has demonstrated sensitivity towards allegers and has cethods in place to receive and resolve allegations.
The applicant has encouraged employees and centractors to take their concerns to supervision, to the management hot-line, or to SAFETEAM. The applicant has met with various allegers to resolve their concerns.
For example, the applicant made presentations and provided plant tours for the Citizens Association for Sound Energy and tio CASE consultants regarding the resolution of allegations and concerns in the pipe support area.
These efforts contributed to the resolution of CASE's piping
,
support issues.
During late 1987 and early 1968, the applicant substantially reduced the nunber of total employees and contractors working on Comanche Peak (about 2500 onsite and offsite).
The NRC received very few allegations, probably six or less, due to the layoff.
This indicates that the programs that the applicant has in place to address employee concerns are effective.
l
e
,
!o' e a
.
- 43 -
TABLE !
ENFORCEMENT ACTIVITY
,
FUNCTIONAL NO. OF VIOLATIONS IN SEVERITY LEVEL AREA DEV. V IV-111
!!
!
l Safety Assessment / Quality Verification
2
0
0 Engineering / Technical Support (SeeNote)
1
0
0 Soils and Foundations
0
0
0 Containment, Major Structures / Steel supports
1
0
0
.
Piping System / Supports
0
0
0 hechanical Components
0
0
0 Auxiliary Systems
0
0
0 Electrical Equipment /
Cables
0
0
0 Instrumentation
0
0
0
,
Plant Operation
0
0
0 Maintenance / Surveillance
0
.2
0
0
0
0 Security
0
0
0 Radiological Controls
0
0
0 Total
4
0
0 NOTE:
This table does not reflect the escalateo enforcerent ac*. ion pending for the lack of effective quality assurance controls during the service water piping coating removal.