IR 05000445/1988001
| ML20149N108 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/22/1988 |
| From: | Hale C, Harrell P, Livermore H NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20149N100 | List: |
| References | |
| 50-445-88-01, 50-445-88-1, 50-446-88-01, 50-446-88-1, NUDOCS 8803010254 | |
| Download: ML20149N108 (31) | |
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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/88-01 Permits: CPPR-126 50-446/88-01 CPPR-127
Dockets: 50-445 Category: A2 50-446 Construction Permit ,
Expiration Dates:
Unit 1: August 1, 1988 Unit 2: Extension request submitted.
Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 '
Facility Name: Comanche Peak Steam Electric Station-(CPSES),
Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: January 6 through February 2, 1988
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Inspectors: O> '22
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C. a e, Reactor Inspector 1 (p graphs 2.b and 3.b)
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J U P. H. Kaprell, Senio( Resident Inspector Date'-
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(paragraph 6)
' V. Wenczel, EG&G (paragraphs 2.a, 2.c, 3.d, and 5)
Consultants:
J. Birmingham, Parameter (paragraphs 2.d-e, 3.a, 3.c, 3.e, 4, and 7)
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'8803010254 880223 PDR ADOCK 05000445
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Reviewed by: M1 u tht m ? ./ d/Datd M/h>
H. H. Livermore, Lead Senior Inspector Inspection Summary:
Inspection Conducted: January 6 through February 2, 1988 (Report 50-445/88-01; 50-446/88-01) ;
i Areas Inspected: Unannounced, resident safety inspection of appli- l cant actions on previous inspection findings, follow-up on viola-tions/ deviations, technical audit program, allegation follow up, applicant management of quality assurance activities, and general )
plant areas (tours). j
Results: Within the areas inspected, no significant weaknesses f were noted but rtrengths were observed in the implementation of the technical audit }'rogram and the applicant's audit program, particu-larly in the audit stcff, the comprehensive scope of audits, and ;
the involvement o. corporate management in the assessment of the quality assurance program effectiveness. During the inspection, i one violation (an inspection procedure was revised without the required review / approval of the Level III inspector, paragraph 6.a)
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DETAILS Persons Contacted
- M. R. Blevins, Manager, Technical Support, TU Electric
- J. C. Finneran, Pipe Support Engineering, TU Electric
- K. M. Fitzgerald, Program Manager, Ebasco
- C. R. Hooten, Civil Engineering Unit Manager, TU Electric
- J. J. Kelley, Manager, Plant Operations, TU Electric
- O. W. Lowe, Director of Engineering, TU Electric
- F. W. Madden, Mechanical Engineering Manager, TU Electric
- E. Odar, Project Engineering Manager, Ebasco
- M. D. Palmer, Plant Evaluation, Nuclear Operations, TU Electric
- B. L. Ramsey, Project Manager Civil / Structural, TU Electric
- D. M. Reynerson, Director of Construction, TU Electric
- M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- A. B. Scott, Vice President, Nuclear Operations, TU Electric
- C. E. Scott, Manager, Startup, TU Electric
- J. C. Smith, Plant Operations Staff, TU Electric
- M. R. Steelman, Comanche Peak Response Team, TU Electric
- P. B. Stevens, Manager, Electrical Engineering, TU Electric
- R. D. Walker, Manager of Nuclear Licensing, TU Electric The NRC inspector also interviewed other applicant employees during this inspection perio * Denotes personnel present at the February 2, 1988, exit intervie . Applicant Action on Previous Inspection Findings (92701) (Closed) Open Item (445/8514-O-01; 446/8511-0-01): This item was opened by the NRC to assure inspection of the TU Electric process for receipt inspection of vendor documents / record '
The NRC inspector determined that the applicant has an established method to receive and review vendor
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documents / records, and that this method was suitably implemented. The following is a summary of the applicant's program for receiving inspection of vendor documents / records, the method used by the NRC to inspect this process, and inspection result TU Electric has one organization that performs the receiving inspection of safety-related non-ASME and ASME procured items for construction. Procedures governing receiving inspection were: NQA-3.09-11.02, Revision 0,
"Construction Receiving Inspection," for non-ASME items; and AQP-11.4, Revision 1, "Receiving Inspections," for ASME items. Both procedures describe the quality re-quirements for the receiving inspection of hardware items and associated vendor documentation / records for compli- l ance with the purchase order (PO); e.g., applicable ]
codes, standards, and specifications. Prior to perform- 1 ing inspection activities, the receiving inspector i obtains a copy of the item's PO which specifies technical l and QA requirements and vendor documentation submittal )
requirements. Received items are then inspected to '
determine that documentation specified in the PO are I present and provide identification, traceability, and item configuration. Specifically, documentation shall indicate the item was fabricated, tested, and inspected in accordance with PO requirements, prior to shipmen Results of receipt inspections are reported on a receiv-ing inspection report (RIR). Attached to the RIR are checklists, which detail acceptance criteria for both hardware and vendor documentation / records (documentation packages). The NRC inspector reviewed the checklist form used since October 1984 to the present, and found them to be essentially unchanged. For those documentation packages (DPs) which do not conform to PO requirements, nonconformance reports (NCRs) are initiated to resolve the identified condition. The RIR is annotated with the NCR number, which signifies the item cannot be used until the identified condition has been resolved. Satisfactory i DPs are transmitted to the permanent plant records vaul l l
To verify implementation of the established procedures for the receiving inspection program and processing of vendor documents / records, the NRC inspector reviewed 12 RIRs with associated checklists; 6 ASME and 6 Non-ASME. The time frame covered by the sample was September 1986 to January 1988. Procedures used in addition to those above were:
ASME CP-QAP-8.1, Revisions 9 and 10, "Receiving Inspection" AQP-11.4, Revision 0, "Receiving Inspections"
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Non-ASME QI-QP-8.02-2, Revisions 3 and 4, "Receiving Inspection Instruction" Three NCRs initiated for deficient DPs were reviewed to assess the process for correcting deficient documenta-tio The NRC inspector determined from the 12 RIRs that each-of the DPs were inspected and processed as require RIRs documented inspection results which were supported by attached checklists. The checklists identified each DP inspected / reviewed, and its status (i.e., satisfactory or unsatisfactory). Vendor supplied material test reports were compared for conformance to technical and quality requirements identified on the PO and applicable codes, standards, specifications and drawings. Finally, for satisfactorily completed RIRs, the DPs were transmit-ted to the permanent plant records vault as require The three NCRs reviewed by the NRC identified nonconform-ing conditions, such as: certified material test report was illegible, certificate of compliance did not properly certify material to PO requirement, and the code case (ASME) used to certify material was not approved by the (
Brown and Root Quality Manual. Based on reviewing '
12 RIRs, 3 NCRs, and associated receiving inspection procedures, the applicant has established and implemented ,
a program to review and control vendor supplied i documentation / records for conformance to PO requirement To further verify that the required documentation was being provided by the vendors and contractors when the procurement is made directly by TU Electric, the NRC
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inspector reviewed Procedure TNE-DC-5-1, "Vendor Document Review." This procedure, among other things, requires TU Electric procurement engineering to assure that vendor document submittals comply with the purchase order documentation requirements. Procurement engineering t personnel prepare a vendor document index (VDI) and vendor document checklist (VDC) for each vendor. The VDC '
lists the documents required by a vendor based on pur-chase order and change order requirements. The VDI lists )
the documents received from the vendor. When a vendor completes their purchase order requirements, procurement engineering would reconcile any disagreements between the l VDC and VDI and then complete Form TNE-DC-5-1.3, "Vendor i Document Index Close Out." This completed form documents !
procurement engineering's verification that the vendor had satisfactorily completed the document submittal requirement l l
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Based on the above inspection, the NRC inspector veri-fled, that procedures are in place and are being imple-mented to not only control the receipt of vendor records, but assure that all required TU Electric vendor documents have been submitted. Accordingly, this item is close b. (Closed) Unresolved Item (445/8514-U-06; 446/8511-U-06):
Chicago Bridge and Iron (CBI) records were shipped off site for copying; however, no control of the records was apparent such as type of shipping container, an absence of backup copies, and no records accountability of the shipmen (This is the same issue identified as ID Recommendations 30, 31, and 32 in Enclosure 1 to Stello's memorandum, "Implementation of Recommendations of Comanche Peak Report Review Group," April 14, 1987.)
The NRC inspector attempted to reconstruct the events related to the shipment of CBI records to Houston in the 1985 time frame. Based on a telephone interview with the CBI QA superintendent that transported most of these !
documents, the following information was found:
(1) CBI would accumulate site-generated documents, by contract, for transportation to their Houston office for microfilming and compilatio j
(2) Shipment of these documents was made when a specific l site contract was complete )
l (3) Shipments were made by the CBI QA superintendent in l a one drawer fire rated file cabinet placed in back j of a pickup truc l l
(4) The documents being shipped were the property of CBI l and were accounted for in accordance with CBI i procedure The NRC inspector revicwed CBI Procedure NRP-1, Revi-sion 7, "Nuclear Records Procedure," which controlled the shipping process described above. This procedure de-scribed how documents were compiled to satisfy the requirements of each contract and how the documents were turned over to TU Electric. The NRC inspector also reviewed the TU Electric contracts with CBI, identifying 20 separate contracts. The first contracts were initiat-ed in the mid 1970s and each required some or all of the activities to be conducted on sit Each contract defined the required documentation and its schedule for submittal to TU Electri At present, all CBI onsite activities have been completed and records turned over, except for one open contract for services on an as required basi __ _
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As mentioned above, CBI Procedure NRP-1 describes how CBI documents were compiled and then transferred to TU Electric. The specific contract identifies the required documentation through imposed specification For example, the first CBI contract, issued in 1974 for Unit 1 and 2 containment liners, required certain docu-ments be submitted before construction (e.g., all calcu-lations and inspection procedures) and others after construction was completed (e.g., certified manufacturer's material test report and heat treatment
- records). This contract has since been completed, but buJore it could be completed, CBI had to satisfy all of the contract documentation requirement In accordance with NRP-1 as a contract was completed or certain documents were judged ready for turnover to the client, they were compiled as directed by the CBI project manager. This compiling included the classification and indexing of document Once this effort was complete, CBI QA was notified that the records were ready for auditing. This auditing would occur at the site or at the home office depending on which location was used to compile the records. When the QA records audit was complete, a transmittal letter was prepared, which listed a description of the documents, their classification, and the number of folder The records were then sent to CBI's Nuclear Records Center in Houston. Transmittal to ,
the Nuclear Records Center was by commercial carrier or hand carried as in the case of this unresolved item, but i
in either case the transmitting organization was responsible for the records until receipt was acknowledged by the Nuclear Records Center. The CBI Nuclear Records Center made two microfilm copies of all hard copies, retaining one film and sending the other film and the hard copies to their client. Shipment to the client was usually by commercial carrier, but on occasion these records were hand carrie The NRC inspector reviewed the vendor record files in the permanent plant. records vault (PPRV) for two of the CBI contracts (CBI Contract Nos. 44361 and 91939). These files were inspected against the documents identified in office memorandum TSG-15,979, "CB&I Required Documenta-
- tion submittals." TSG-15,979 identified the type of documents required by several of the CBI contracts. The documents identified were compared to the file index for each of these contract files and then the file index was compared to the actual documents in the file. The file index for Contract 44361 listed three folders under file Classification 9.0, "Work Packages," but only two folders were in the contract file. An immediate search of nearby files for the missing folder was unsuccessful, but within a few hours, the PPRV perscnnel had obtained certified
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l 8 copics of the documents in the missing folder from the microfilm of all the contract documents that accompanied the records shipment from CBI. When, or.if, the missing folder is found, it will be placed in the contract file and the certified copies destroye To assure that the documents required by the CBI con-tracts were indeed provided, the applicant performed a special audit of the largest CBI contract file in June 1986. The special audit, perforned by personnel from Daniel, was a comprehensive review of the contract and specification requirements for documentation on CBI contracts 74-2427 and -2428. The NRC inspector reviewed
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the Daniel audit results for this CEI contract
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(containment' metal liner, hatch, and air locks). Ten concerns were identified but only four related to documentation that was not provided by CB (For perspective, the documents for Contracts 74-2427 and -2427 fill more than four standard file cabinet drawers.) All concerns were resolved and the additional documentation was provided from the CBI Nuclear Records l
Cente In summary, the NRC inspector found that CBI records were shipped from the site to the records center in Houston for copying. This process was accomplished in accordance with.CBI procedure Copies were not retained on site, nor were they required to be; however, accountability was maintained by use of document transmittal lists. No violation of CBI or TU Electric procedures were identi-fled; therefore, this unresolved item is being close (Closed) Open Item (445/8724-o-01; 446/8718-0-01): This l open item pertained to the resolution of a significant l deficiency analysis report (SDAR-125). The issue was l whether defects found in installed steel manufactured by l Northwestern Steel and Wire (NSW) was specific to Heat No. 7076 To address this issue, the applicant accomplished the following actions. The site procurement records (pur-chase orders) were reviewed to identify steel (by heat l
number) obtained from NSW. Associated field fabrication and installation records were reviewed to identify locations where material was installed in safety-related applications. Of the 244 locations identified, all were visually inspected for surface. defects; areas of the I beams inspected were the flanges and webbs including the fillets. No additional surface defects were identi-fle The NRC inspector reviewed the applicant's inspec-tion results and supporting documentation. Based on l
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documentation reviewed, it was determined that defects previously identified in installed steel from Heat
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9 No. 70763 were heat number specific and not generic to other heats obtained from NS d. (Closed) Unresolved Item (446/8724-U-02): During a plant tour of the Unit 2 cable spread room, the NRC inspector identified that beveled washers were not used on certain 4-inch beams having tapered flange Subsequent investigation of the above unresolved item by plant personnel identified that nonconformance report (NCR) M-85-100083-S had previously been issued to identi-fy a generic concern relative to the proper use of bevelled washers in the Unit 2 cable spread roc Additionally, the engineering department had identified the beams likely to be nonconforming. Although the NCR addressed the nonconforming condition, the NRC inspector had other concerns relative to the proble Specifical-ly, the NRC inspector was concerned that the NCR was open almost three years after issuance. The NRC inspector was concerned that corrective actions on other NCRs may have been untimel During a meeting with the TU Electric director of QA and the TU Electric engineering assurance (EA) manager, this concern was discussed. The director of QA informed the NRC that currently over 10,000 open NCRs existed and that of these, some had been open two or three year The 4 large number of open NCRs was deemed to have arisen, for the most part, from reinspections performed by the CPRT and from walkdowns performed as part of the corrective action programs (CAP). The EA manager stated that because of scheduling some NCRs did remain open two to three year For example, the NCR on improper use of bevelled washers was written for the Unit 2 cable spread room and therefore was of a lower priority than Unit 1 NCRs. The NRC inspector expressed a concern that the large number of NCRs must be reduced. The EA manager stated that a reduction in the number of open NCRs was ,
expected to begin as the CAP engineering walkdowns neared I
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completion and the emphasis changed to completion of rework. Since TU Electric is aware of the concern relative to open NCRs and appears to be scheduling the close out of NCRs, the NRC inspector considers the response to this concern acceptable. The unresolved item is closed based on the prior identification of the problem and its documentation on an NC e. (Closed) Open Item (445/8706-o-25): A review of corrective action reports (CARS) performed by the CPRT l did not assess the technical adequacy of the CAR disposition.
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This open item was addressed by the applicant in response to Violation 445/8607-V-24. That violation related to CAR-049 which was closed with an inadequate dispositio (See paragraph 3.c of this report.)
The corrective actions taken for that violation included a 100% review by TU Electric of the technical adequacy of the CAR dispositions. The CARS reviewed included B&R CARS, Dallas QA CARS, construction CARS, and operation CAR The NRC inspector has reviewed the corrective .
actions taken fer Violation 445/8607-V-24 and determined that they satisfactorily address this ite This item is closed, t
3. Follow-up on Violations / Deviations (92702) (Closed) Violation (EA 86-09, Appendix A, Item II.B):
This item refers to an NRC Technical Review Team (TRT)
finding that contrary to site procedures work in the '
onsite fabrication shop was performed in accordance with a material requisition (MR) and that the controlling
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paperwork (i.e., controlled drawing, hanger package, or traveler) may not have been at the location where the work was performed. The TRT determined that this action was a violation of site procedures. The TRT found that the QC inspections and material traceability were record-ed on the MR. The applicant waJ notified of the viola-tion via NRC letter EA 86-09 dated May 2, 198 *
The NRC inspection of the corrective action for this item i was initially performed in June of 1986. At that time the NRC inspector reviewed current MRs and fabrication packages and determined that fabrication shop activities were in compliance with procedures. The NRC inspector identified a concern related to this item in that the controlling procedure for MRs (CP-CPM-7.3A) was inade-quate and, therefore, this item was not close During this report period, the NRC inspector reviewed !
four fabrication packages currently being worke These '
packages were found to properly provide controlled drawings, inspection sheets, and material identity log The NRC inspector discussed the requirements of Brown &
Root (B&R) Procedure PS-ACP-ll.5, Revision 2, "Component Support Fabrication," and TU Electric Specification i 2323-SS-16B, Revision 1, "Structural Steel / Miscellaneous Steel (Category I and II.)," with two of the shop fore-men, two craftsmen, and a QC inspector all in the fabri-cation sho Each of the above personnel was knowledge-able of the procedure Since (1) the preparation of MRs l was found to be in compliance with procedural require- '
monts, (2) current implementation of fabrication shop l
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I activities utilizes the controlled drawings, hanger '
package, or traveler as required, and (3) fabrication shop personnel are knowledgeable of fabrication shop procedures, this item is close (Closed) Violation (445/8514-V-02; 446/8511-V-03):
Certain design documents were shipped from the site to
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-the New York offices of Stone and Webster Engineering Corporation (SWEC) without procedures being established I
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and implemented for the control of these QA record These design documents were shipped in cardboard boxes, no backup copies were retained by the site, and no accountability of documents shipped or received was maintaine (This item was.also identified as ID Recommendation Nos. 26 through 29 in Enclosure 1 of the Stello Memorandum, "Implementation of Recommendation of Comanche Peak Report Review Group," dated April 14, l 1987.)
l l From interviews and document reviews, the NRC inspector i established the followin By letter, dated August 1, 1 1985, the first in a series of document shipments was
! sent from the site to the SWEC New York office These
! documents were calculation packages bound in folders, each folder containing numerous pages for all ASME large bore pipe supports Classes 2 and 3. Other large bore
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pipe supports calculation packages were also sent, but l the majority were for ASME Class 2 and 3 pipe support These calculation packages were taken fran the pipe support engineering document files. They were the original calculations and no backup copy of the calcula-tions was retained at the site. Each document shipment was transmitted with a letter which listed each calcula-tion package in the shipment and required receipt ac-l knowledgment for the shipment. The transmittal letter did not list the number of pages in each calculation '
package; however, the pages in each package were bound in ;
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folder This process continued for 14 shipments for a l
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total of approximately 100 calculation packages amounting to several thousand pages, the last shipment being !
! October 12, 1985. On October 16, 1985, the NRC inspector l
identified this process as being in violation of require-ments; however, a procedure was in place during this time period and had it been followed the violation would have been avoided, l
TUGCo Nuclear Engineering (TNE) Procedure TNE-AD-4, )
"Control of Engineering Documents", Revision 6, stated in l Figure 1 that the Document Control Center (DCC) would !
make and retain a copy of completed calculations and design verifications that were distributed externall !
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In response to the identified violation, TNE Procedure i TNE-AD-4-6, "Transmittal of Pipe Support Engineering !
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Calculations", was issued November 25, 1985. This ,
i procedure more specifically implemented the requirements !
of TNE-AD-4 concerning the calculation package shipments i to SWEC. Section 2.3 of Procedure TNE-AD-4-6 required, i
- "If the original calculations are transmitted, copies ,
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shall be maintained in the PSE files." TNE-AD-4-6 .
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. replaced TNE Procedure CP-EI-18.0-4, Revision 0, dated '
- July 25, 1985, which had the same title and same instruc-
, tion, but had failed to require the site to retain copies of documents shipped to SWEC. In addition, SWEC was
requested to return to the site copies of all documents sent to them during the period from August 1 to ,
j October 12, 1985.
l For those documents shipped to SWEC between August 1 and October 12, 1985, the NRC inspector verified the follow-
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ing by review of transmittal letters and TU Electric
- document accountability sheets:
(1) All calculation packages sent from the site were acknowledged received by SWEC.
l (2) All calculation packages sent from the site were
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copied by SWEC and returned to the site, the last >
i shipment being December 9, 1985,.and site personnel ,
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had completed verification that-all had been re-turned by February 1986,.this being accomplished by !
comparing the copies received from SWEC to the !
transmittal record of the calculation packages ;
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- On November 5, 1985, the site resv.med shipment of calcu-lation packages to SWEC in accordance with TNE-AD-4 and
! TNE-AD-4-6. These shipments continued until March 24, l 1986, the date of the last large shipment of document The NRC inspector found no other occurrence of procedure
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violation in these shipments; i.e., copies were made and ;
retained at the site prior to shipmen As noted earlier, the only calculation packages involved in these shipments were for large bore pipe support l The NRC inspector discussed the status and use of these
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calculation packages with TU Electric and SWEC managemert I personnel. Of significance from these discussions was the fact that the calculations obtained from TU Electric were hardly used if at all by SWEC. According to SWEC personnel, the only documents used in the packages were reference copies of drawing The SWEC and TU Electric
. personnel stated further that every pipe support calcula-tion involved in these shipments has been superseded.
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SWEC has reperformed all of these calculations and the i SWEC calculations are now the calculations-of-recor l l
All of the original calculation packages are being )
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returned to TU Electric. Only a small percent remain in the custody of SWEC and even these are awaiting return to TU Electric. At present TU Electric is holding these calculation packages in the engineering records cente l The records engineer in charge of this center stated that .
there are no plans to dispose of these calculation l packages even though they have been supersede l l
The NRC inspector is closing action on this item based on l the foregoing and the further consideration that: (1) all I of the original calculation packages were accounted for and (2) none of the original calculations are now the
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calculation-of-recor I c. (Closed) Violation (445/8607-V-24): This violation concerned closure of CAR 049 prior to completion of i corrective actio The applicant performed a review of all CARS issued by j TU Electric and B&R closed previous to December 22, 198 l The review of CAR disposition = wa* performed to determine l if the dispositions were appropriate to the identified 1 concern and whether the dispositions were sufficiently implemented to justify CAR closur The NRC inspector reviewed 15 B&R CARS and 35 TU Electric I CARS issued by construction, operations, and the former {
Dallas based TU Electric audit group. From the review i the NRC inspector determined that the identification of root cause, corrective actions, and the actions to preclude recurrence were adequate to justify CAR closur l The NRC inspector also performed a review of the applicant actions taken to verify the above item For example, the CAR files contained copies of the training records or procedural revision required by the i CA The NRC inspector noted that early CARS did not I always provide such backup documentation. Those CARS ,
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that did not have backup documentation were found to have statements and/or signatures that corrective actions had l been verified. This practice was in keeping with the l procedural requirements for that tim The NRC inspector reviewed additional files, letters, and memoranda prepared during the applicant's review of the CAR files. The files and memoranda showed that the applicant had performed additional actions for seven CARS and that verification of corrective actions was performe The NRC inspector reviewed these additional I
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actions and determined that they were proper. Based on the NRC inspector's evaluation of the 50 CARS and the review of the applicant's additional actions the NRC inspector determined that the review of CARS was satis-factory and that this violation is close d. (Closed) Violation (445/8718-V-04; 446/8714-V-03): The package inventory card and the electrical construction documentation package did not agre The applicant responded to the condition identified by the NRC inspector when the contents of 10 electrical penetration assembly documentation packages (inventoried by the paper flow group (PFG) distribution satellite) did not agree with the corresponding package inventory card (PIC). Specifically, the number of megger data sheets, contained in the documentation package as an attachment to Procedure EEI-22, "Installation of Conax Feedthrough/ Adaptor Module Assemblies into Amphenol Sams Penetrations," were not consistently identified on the PI The applicant committed to: (1) institute a stan-dard method for designating procedure attachments on the PICS; (2) train appropriate PFG personnel to the standard I methods to be used to designate procedure attachments in l the PICS; and (3) review all electrical penetration j assembly documentation packages and revise the PICS, as '
necessary, to indicate the correct number of megger data sheets contained in the package I The NRC inspector verified completion of the above actions by documentation reviews and personnel inter-views. Written and verbal instructions were given to both old and new employees concerning the standard method ,
for designating procedure attachments on the PIC (i.e., l EEI-22, Attachment 1). To resolve possible ambiguities revised Procedure CP-CPM-7.lB, "Electrical," has been issued using Document Change Notice (DCN) 6. This revision provides further clarification on the standard method for documenting procedure attachments on the PI Approximately 430 EPA documentation packages were reviewed by PFG personnel to assure consistency between the PIC and the documentation package. The NRC inspector reviewed 20 packages for consistency. These packages were determined to be correc Dased on documentation reviews, which substantiated the completion of actions committed by the applicant, this violation is close e. (Closed) Deviation (445/8729-D-01): During a field inspection performed for Verification Package I-M-VII.a.9-082, the CPRT inspector incorrectly verified
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a 1/2" NPT opening as being 3/4" NPT. The opening was specified by Drawing 102202E as a drain for the turbine casing of the turbine driven auxiliary feedwater pump for Unit The CPRT reinspected the above condition and determined the CPRT inspector was in error. The inspection check-list for the verification package was corrected and deviation report (DR) I-M-VII.a.9-082-01-DR5 was issued to document the incorrect connection size. The CPRT 2nspection Supervisor reviewed the inspector's past performance and determined that the deviation was an isolated occurrence. The NRC inspector reviewed the corrected inspection checklist and DR I-M-VII.a.9-082-01-DR5 and determined that CPRT had properly documented the nonconforming condition. The NRC inspector reviewed the results of the CPRT inspection supervisor's review of the inspector's past performance and concurs that the deviation appears to be an isolated occurrence. The responsible CPRT inspector is no longer employed by CPRT; therefore, retraining is not require This item is close . Technical Audit Program (35060)
The activities of the TU Electric technical audit program (TAP) were previously inspected and documented by the NRC inspector in NRC Inspection Report 50-445/87-24; 50-446/87-1 At that time the NRC inspector: (1) evaluated the procedure controlling the TAP, NQA 3.07-1.01, "Technical Audit Program",
(2) reviewed the qualifications of TAP audit personnel, and (3) inspected, in detail, the records of four TAP audit During this report period, the NRC inspection activities included: (1) review of the changes incorporated in the TAP controlling Procedure NQA 3.07-1.01, Revision 1; (2) review of the qualifications of additional TAP audit personnel; (3) inspection of the records of four TAP audits performed at contractor's offsite offices (e.g., Audit ATP-87-75 which was performed at Impell's regional office in Lincolnshire, Illi-nois); (4) detailed inspection of Audit ATP-87-69 (which was an evaluation of conduit supports design validation performed on site); and (5) review of previous audits to determine whether the content of audit checklists changed appropriately as the CAPS change Review by the NRC inspector of the changes incorporated into NQA 3.07-1.01 determined that the changes were minor in nature and were added to improve the procedure's clarity. For example, one cnange to Procedure NQA 3.07-1.01 provided updated references to these procedures by which the training, indoctrination, and certification of auditors and lead audi-tors were to be accomplished. The changes to the controlling I
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procedure were considered appropriate and did not lossen the scope nor the controls in place for the TA The NRC inspector reviewed the qualifications of five TAP audit personnel, including two technical specialists used by the TAP on an as needed basis. The qualifications were inspected by a review of the personnel resumes maintained by the QA training group. The results of this review showed that each individual had received indoctrination and training in those ANSI standards and TU Electric procedures related to the TAP. Each of the individuals was found to be a degreed engineer with approximately 15 years of experience relating to nuclear industr Audit records resulting from TAP audits conducted at offsite offices of Stone & Webster, Ebasco, and Impell were inspecte Specifically, the audit checklist and audit reports were reviewed to determine whether: (1) the checklists sufficiently covered the scope of the work being audited; (2) the check-lists were sufficiently detailed to assure that the technical approach, use of design criteria, use of computer programs, calculations, document preparation, and consideration of generic technical issues were acceptable; (3) deviations from requirements or errors in calculations were identified as deficiencies or observations in the audit report; and (4) follow-up of deficiencies was accomplished in an appropriate and timely manne The NRC inspector reviewed completed audits ATP-87-51, ATP-87-56, ATP-87-58, and ATP-87-75. A typical example of these audits is ATP-87-51. Audit ATP-87-51 (performed at the New York office of Ebasco) reviewed five design basis documents (DBDs), thirty-one calculations, two design change authorizations, four drawings, and six design issue resolution The checklist for ATP-87-51 consisted of 127 items. These items included: (1) specific questions on generic technical issues such as adequacy of HVAC heat loads; (2) programmatic questions on the general design process such as whether procedures, specifications, and drawings used for design evaluation are approved and current; (3) specific questions for DBDs such as were source documents properly identified, were all of the applicable Regulatory Guides identified, and were environmental conditions clearly identified; (4) questions designed to assure the adequacy of calculations such as was the calculation properly reviewed, was reference information properly transferred, and were equations appropriate for intended use; (5) generic questions on drawings such as were drawings relative to safety clearly identified as safety-related, were engineering symbols used adequately defined, and were interface drawings referenced; (6) questions on specifications such as does the specification provide sufficient design data (pressure, temperature, flow),
has the interdisciplinary review been performed properly, and
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were service conditions correctly identified; and :
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(7) questions on design issue resolution such as does the I resolution respond to the concern raised, and does the response provide an auditable trail to the design documen Based on review of the completed checklists, the evidence observed by the audit team, and the audit team's evaluation of -
4 the evidence, the NRC inspector determined that the audit scopes were appropriate for the work being audited and that :
the audit checklists were sufficiently detailed to assess the i i
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In order to assess audit performance, the NRC inspector reperformed, in part, Audit ATP-87-69. Audit ATP-87-69 had L j been performed by the TAP, November 2-6, 1987, at the Ebasco
- onsite office. The audit was of the technical adequacy of the Ebasco conduit support design validation program. The NRC inspector reviewed the audit report, audit checklist, and the correspondence relative to follow-up actions on audit defi-ciencies. The NRC inspector performed the assessment of Audit ATP-87-69 in light of the purpose of the audit as stated on I
the audit reports (1) determino that Ebasco's calculation packages are in compliance with applicable procedure require- t ments; (2) verify that as-built or as-installed configurations are factored into the Ebasco design validation process; (3) r
- examine and assess calculations to determine technical accura-cy and compliance with applicable engineering codes and standards; (4) verify that corrective actions to resolve
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generic technical issues are appropriately addressed; and (5)
1 verify that completed documentation is being accumulated and packaged in accordance with approved program and procedure requirement For this audit (ATP-87-69) the TAP audit team reviewed 17 con-
duit isometric verification packages, one individually ana-lyzed support calculation package, and one generic calcula-tio In reperforming the audit, the NRC inspector reviewed three conduit isometric verification packages and one generic
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calculation. Specific packages reviewed were Conduit Isomet-ric Verification Packages 05201, 06156, and 06285 and Generic Calculation TNE-CS-CA-CA-l i
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The NRC inspector found the audit checklist to consist of specific questions designed to assess the programmatic imple-mentation of the conduit support design validation packages as 4 well as the technical adequacy of the packages. For example, the checklist included specific items, such ass (1) verify that completed documentation is accumulated and packaged in accordance with approved progrmn and procedure requirements;
(2) verify dynamic amplification factors (design "g" valves)
i are in accordance with Procedure SAG.CP10; (3) verify bolt i hole tolerances and edge distances are in accordance with the requirements of SAG.CP10 and AISC code. The NRC inspector
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completed the audit of the three verification packages and .
, compared the results to the TAP audit results. Although the 1 NRC inspector noted a negligible arithmetic error not identi- i fled by the TAP, the results of the two audits were essential-
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ly the sam ,
The purpose of generic calculation T3E-CS-CA-CA-la was to evaluate the allowable capacities of certain generic supports l found in Drawing 2323-S-0910 utilizing the results of actual l
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field test In assessing the TAP actions performed relative
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to auditing TNE-CS-CA-CA-la, the NRC inspector used the following criteria (1) were the calculations used to deter-mine the allowable loads accurate; (2) were the adjustments '
made to allowable loads appropriate; (3) were the test config-urations sufficiently varied to allow the establishment of generic allowable loads for each type of support; (4) were engineering assumptions clearly stated and appropriately -
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applied; and (5) were conclusions reasonable. Upon comparing the results of the NRC inspector's assessment and the TAP '
assessment, the NRC inspector determined that the TAP assess-ment was acceptabl Based on review of the three conduit support verification packages and the generic calculation, the NRC inspector
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determined that the TAP audit implementation was acceptabl The NRC inspector determined that Audit ATP-87-69 was primari-
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ly technical in nature rather than programmatic. The approxi-mate percentage of checklist items of a technical nature was 75%. This percentage is considered appropriate and in keeping I
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with the intent of the TAP. A review of earlier audits of the Ebasco onsite work scope such as Audit ATP-87-01 showed a ;
higher percentage of programmatic checklist item The i
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emphasis on programmatic implementation is considered appro-priate for the early stage of the Ebasco work in order to assure the timely development of procedures, their effective- !
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ness, and the conduct of training on procedures to implement
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No violations or deviations were identifie Further NRC inspection of the TAP to verify continued implementation is :
planne . Allegation Follow-up (99014)
(Closed) Allegation (OSP-86-A-0151): Five concerns were !
submitted to TU Electric for consideration and action. Of the i five concerns, four were nonsafety, and one was potentially ,
safety-related. The following is a description of the con- i corns, TU Electric actions, and actions taken by the NR i l
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a. Nonsafety-related concerns These concerns were addressed by TU Electric as described below and no further NRC action is planne (1) There was cracking of the main condenser tube sheet A similar concern was addressed by the NRC
in NUREG-0797, Safety Evaluation Report, Supplement 8, page K-113. The applicant has since replaced the tube bundles which includes the tube sheets, for both Unit 1 and 2 condenser (2) The radius taper of the Squaw Creek Reservoir (dam)
is not in accordance with design. The fill for the dam was made in some cases in 18-inch lifts versus the 6-inch lift specified by procedure. SAFETEAM assessed this concern and determined that the slope (taper) and configuration (radius) of the Squaw Creek Reservoir conforms to the established design requirements for the dam. The lifts were found to be accomplished in accordance with lift thickness requirements. Further, the dam's structure is being monitored by the Texas Department of Water Resources on a semiannual basis. Monitoring results indicate the structure is performing its designed functio (3) The main circulating water pump intake baffles were improperly installed and the proper weld procedures were not followe In addition, the stop gates for the main circulating pump were not properly attached structurall (Stop gates are used to isolate / seal the water inlet from the lake to permit access to the pump's lower unit for maintenance activities.)
The applicant reviewed documentation for the installation of the Unit 1 and 2 circulating water pumps. Based on this review, no evidence was found to indicate the intake baffics and stop gates were i not properly installed. Further, the Welding Procedure Specification 88032, used for installation welding, was determined to be the proper procedur Accordingly this concern was not substantiated by 1 TU Electric and no other actions were take l (4) There was cracking of the cavity liner plate The alleger recommended the cracking problem be looked ,
at generically based on lot and heat number. This l
concern refers to a cracking problem associated with '
the refueling cavity stainless steel liner for !
Unit The allegation was substantiated in that !
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cracking existed in eight liner plates for Unit 2 in both the weld and heat effected zones. The
condition was evaluated for generic implications, but none were found. The applicant determined
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cracking was a function of construction activities and was not inherent to lot or heat number. The cracks were repaired. In addition, fuel pool liner wolds were reinspected and the results documented in ISAP VII.c, Appendix 24. Fuel pool liner documentation was reviewed and the results documented in ISAP VII.a.8. The refueling cavity has been reclassified as nonsafety-related by the applicant, based on the function of the liner plate Reclassification by the applicant has been reviewed and accepted by the NRC (NUREG-0797, supplement 10, page N-287, Reference 8.[4)).
b. Safety-related concerns Two or three 5 gallon cans of trash were not removed prior to concrete placement in the Unit 1 containment wall at a location 50 feet from the personnel air lock and at the same elevation as the personnel air loc Review The NRC inspector reviewed the assessments accomplished by the SAFETEAM, QC, and engineering to resolve the concern. The results of these reviews follows:
SAFE 12AM reviewed concrete placement inspection records to determine if the suspected condition had ever been identified by QC inspectors. One of the prerequisites to concrete placement is QC's verification of cleanlines In addition, the NCR computer printout log was reviewed ,
to see if the suspected condition had been reported on an NC Neither the reviewed inspection records nor the NCR log identified Sny condition involving trash cans in concrete forms prior to concrete placement, as allege Proceeding on the assumption that the alleged condition occurred but was not detected, TU Electric had an engi-neering evaluation performed. This evaluation was to
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determine what, if any, corrective action should be taken given that two or three 5 gallon cans of trash wero !
present in the containment wall as alleged. The engi- !
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neering evaluation was initiated by an NCR (C86-103255).
Once the NCR was issued to track and resolve this con-cern, the SAFETEAM considered its involvement close The NRC inspector reviewed NCR C86-103255 and the sup-porting engineering documentation. The NCR was dispositioned use-as-is with no actions required. This !
disposition was based on an engineering calculation that i addressed the effects of the trash cans on the structural l integrity and radiological shielding at the identified '
location. Methods used in the calculation postulated the position of the buried trash cans to be that which would l
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result in the maximum available concrete void. No adverse effects were found to exist if three 5 gallon trash cans had been left in the concret Conclusion The allegation could not be substantiated. The applicant performed an engineering evaluation to determine if any adverse effects on containment wall integrity or shield-ing would have resulted if the alleged condition did exis None were identified. With the absence of any safety significance regarding this concern, the allega-tion is close . Applicant Management of Quality Assurance Activities (35060)
The NRC inspector performed a review to determine the offec-tiveness of applicant management and implementation of the corporate QA program for ongoing activities of design, pro-curement, and construction. Within this area of the inspec-tion, a number of elements of the QA program were reviewe Each area is discussed below, Corporate QA Organization and Its Function This element of the QA program was reviewed to verify that the applicant had established an adequate organization for controlling QA activities. The following items were considered during this revie The applicant's overall organization was structured such that the QA organization maintained organizational freedom assuring that sufficient independence from cost and schedule pressures existe The NRC inspector reviewed the applicant's overall organization chart, as shown in Figure 17.2-1 of the Final Safety Analysis Report (FSAR), in conjunction with the description of each organization's functional responsibilities, as stated in Chapter 13 of the FSA During the review, the NRC inspector noted one case where freedom from cost and scheduling considerations was not apparen The QA and Reactor Engineering organizations report to the Vice President, Nuclear Engineerin Although no problems were noted at this time, the potential for the cost and scheduling pressures experienced by the Reactor Engineering organization may adversely impact the organizational freedom of the QA oxganization when the plant enters an operating mod The Reactor Engineering organization performs unique functions during refueling outages that permit plant startup at the completion of the outage. Since the QA organization performs audits of the Reactor Engineering
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organization, the NRC inspector was concerned that the audit findings identified by the QA organization may not receive proper management attention when weighed against the need for the Reactor Engineering organization to complete its refueling outage activitie This item was discussed with applicant management personnel. Although management personnel did not believe a QA organization independence problem existed, the personnel stated that an organizational review would be performed. This item will be reviewed during a future inspection (445/8801-0-01; 446/8801-0-01).
No other problems with the applicant's organizational structure with respect to the independence of the QA organization were identifie The management personnel qualifications for the positions of Director, QA; Manager, QA; Manager, Operations QA; and Manager, QC were stated in Chapter 13 of the FSAR. The NRC inspector reviewed the resumes for the individuals currently holding these QA management position According to the information provided on the resumes, each QA manager exceeded the stated FSAR qualification No problems were noted by the NRC inspecto Procedures were established by the QA organization to impicment the QA program requirements, as stated in Chapter 17 of the FSAR. The NRC inspector reviewed selected procedures from the applicant's operations, Startup, and Design and Construction QA programs. The applicant had established a QA program to provide specific QA instructions for the different activities associated with design and construction, startup, and operation of the plant. Based on a general review of the applicable procedures, it appeared that the applicant had provided adequate instructions for the implementation of these different activitie The NRC inspector reviewed the performance of QA-related activities to verify that the activities were performed in accordance with approved procedures. The verification was performed by reviewing completed QA documentation and discussions with individuals involved in QA activitie <
During the review, the NRC inspector noted that the applicant had failed to comply with Procedure NQA 1.03,
"Development, Revision, Control and Distribution of TU Electric NEO Quality Assurance Department procedures,"
Revision 3, dated October 5, 1987. The failure to comply with Procedure NQA 1.03 was related to the failure of the appropriate individual to review a change to a procedure prior to issuance of a revision, i
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Critorion V of Appendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall be prescribed by documented procedures, of a type appropriate to the circumstances, and shall be accomplished in accordance with these procedure Paragraph 6.7.3 of Procedure NQA 1.03 stated that NDE and inspection procedures require the approval of the discipline Level III inspector. Paragraph 6.5.1 of Procedure NQA 1.03 stated, in part, that a DCN shall be forwarded to the appropriate Level III (if applicable),
the Section Manager, and the Director, Quality Assurance for approva Contrary to the above, DCN 3 to Procedure NQA 2.09-5.01,
"Inspection of Instrumentation Components," an inspection procedure, was issued without the approval of the discipline Level III inspector. DCN 3 revised the technical content of irspection Procedure NQA 3.09-5.01 (445/8801-V-02; 4 4 6/8 8')l-V-02 ) .
Based on the re/lew performed of these QA-related activities, it appeared, except for the one example cited -
above, that the applicant was properly implementing procedural rear.irements, b. Applicant Reviews of the OA Program Effectiveness This portion of the inspection was performed to verify that the applicant was adequately reviewing the effectiveness of the QA program. The following items were reviewe Audits were performed by the internal audit group to assess the effectiveness of the QA program. The audits included reviews of the operations, startup, contractor, and design and construction QA programs. The NRC inspector reviewed seven 1987 audits performed by the internal audit group on the operations, construction, startup, and design organizations. The NRC inspector noted that each of the audits reviewed was well structured, adequately evaluated the QA programs, and was performed by qualified individual In each case where a deficiency was identified by the audit team; the deficiency response was provided within the specified time frame, the deficiency response contained adequate corrective actions, and the actions were taken in a '
timely manner. No problems were noted during review of this ite The effectiveness of the QA program was evaluated through i
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audits by an organization independent of any of the applicant's organizations. The NRC inspector reviewed i
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such an audit performed by the Joint Utility Management Audit (JUMA) group. The JUMA group was composed of personnel from other utility companies with QA backgrounds, including two individuals with direct QA responsibilities. The audit was performed in the areas of internal audits, technical audit program, vendor compliance, quality engineering, and quality surveil-lanc A review of the audit indicated that one deficiency war noted in the area of vendor compliance and observations in the other areas. No problems were noted that compromised the overall effectiveness of the QA program. The applicant provided adequate corrective action to the deficiency and observations identified by the JUMA grou No problems were noted during evaluation of the applicant's program for evaluating the effectiveness of the QA progra c. Corporate / site OA Interface This area was reviewed to determine the adequacy of the corporate / site QA interface and to verify that applicant upper management was routinely informed of the status of the QA program. This review was performed by evaluation of the following item The onsite QA management routinely reports the status of the QA program to corporate management through an annual report that is published and provided to corporate management for review. The report, "Annual Assessment of the overall Effectiveness of the QA program," compiled
, data gathered over the preceding year and discussed the
- areas of the QA program that need additional management attentio After review of the report by corporate management, action items were assigned by the QA overview committee to the plant staff for completion. The items assigned were structured to ensure that the adverse QA trends were corrected. During follow-up meetings of the QA overview Committee, adequate completion of these action items will be verified.
i The NRC inspector reviewed the annual assessment report issued for 1986. The NRC inspector noted that the report was comprehensive and identified areas where additional management attention was required. The areas identified in the report appeared to be appropriately developed based on the data provided in the report. The NRC inspector also noted that action items had been appropriately assigned based on the report conten The ,
action items were assigned and follow up provided, as {
discussed belo '
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l Regularly scheduled reviews of the QA program were performed on site to evaluate the QA program '
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offectiveness. The onsite review meetings were attended by corporate personne ;
The applicant established an onsite QA overview committee (QAOC) to review the implementation of the QA program each mont Each of the monthly meetings was attended by a representative from the corporate management l organization. At the meetings, QA weaknesses were ,
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identified, discussed, and actions assigne In addition, the action items assigned during review of the annual assessment of QA program offectiveness by ,
corporate management were tracked to ensure timely and !
adequate closcout of the items. The QAOC reviewed trend reports that were published monthly by the manager, Operations QA. A review of the trend reports by the QAOC resulted in the identification and assignment of additional action items to the appropriate individual NRC representatives have attended several of the QAOC meeting The NRC inspector reviewed recent meeting minutes (May i 1987 through october 1987) of the QAOC to verify that QA l program weaknesses were identified and action items l assigned. The review included a verification that the I action items assigned, based on the annual assessment, l were addressed and corrective actions taken. In this I review, it was also verified that the monthly trend l raports on the QA program were reviewed by the l appropriate levels of management. Based on the reviews l performed by the NRC inspector, it appeared that tho l applicant had established a program that would ensure an acceptable interface was maintained between the site and corporate QA organization No problems were noted during the review of the corporate / site QA interface program. Evidence reviewed indicates a strong involvement of corporate management in l the total QA progra l l
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d. Design Program Review This element was reviewed to verify that the applicant had established a program for control of QA design activities by the contractor design organization. The items reviewed in this area are discussed belo The organizational structure that defined the lines of responsibilities between the applicant and the design contractor were established. The NRC inspector reviewed procedures to verify that interfaces betwoon the applicant and contractor had been adequately establishe The review focused on the methods used for approval of design documentation and subsequent changes to the documentation within the contractor's organizations, receipt and handling of design input from organizations
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outside the contractor's organization, and the l applicant's review of documentation to verify that the design provided by the contractor was adequat The principal design contractor performed its safety-related design activities within the requirements established by an approved QA program. The NRC inspector verified that the applicant had performed a review and accepted the contractor's QA program as described in their QA manual. The NRC inspector also reviewed six procedures in the contractor's QA manual to assure that the contractor's defined interfaces correlated with the interfaces established by the applicant. The review of selected procedures also verified that the contractor had established an appropriate overall QA progra Audits were performed by the applicant of the contractor's QA activities related to design effort The NRC inspector reviewed four audits that were performed. The NRC inspector noted that the audits were comprehensive, provided an in-depth review of the activities, and were performed by qualified individual For the items reviewed, it appeared that the contractor provided timely corrective actions for the deficiencies identified by the auditors. Based on a review of the audits performed, it appeared that the applicant was adequately monitoring the contractor's design activitie No problems were noted during the review of this portion of these inspectio c. Procurement Activities This element was reviewed to verify that the applicant had established a procurement program in accordance with the applicable regulations and that the program was being implemente The items reviewed are discussed belo I
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The applicant had established a program for issuing and maintaining an approved vendors list (AVL) and implemented the requirements of the program. The NRC inspector reviewed the program established by the applicant for qualification of vendors, suppliers, and contractors that were included on the AVL and reviewed the program for maintaining an organization on the AVL once initial qualification was established. Included was a review of procedures, vendor initial qualification documentation, and the documentation generated to main-tain a vendor on the AVL. The review also included discussions with personnel responsible for implementation of the program.' It appeared that an adequate program had been establishe purchase orders and/or contracts were issued to vendors that were properly qualified by audit or source inspection. The NRC inspector reviewed purchase orders and contracts to ten different suppliers to verify that the purchase document was issued to a vendor that had been qualified prior to issuance of the purchace document. In each case reviewed, the vendor had been properly placed on the AVL prior to issuance of the procurement documentatio In addition, each procurement document contained, as appropriate, a statement noting that 10 CFR part 21 was effective for the vendor providing the material or servic Audits were performed on vendors in accordance with established requirements to properly qualify vendors for inclusion on the AVL. The NRC inspector reviewed four audits performed by the applicant on vendors that had been placed on the AVL. The audits reviewed by the NRC inspector were completed in accordance with established requirements, were performed by qualified individuals, and were of sufficient depth to assure that the audited organization adequately implemented an effective QA progra An audit schedule had been established to assure that vendor audits were performed on a regularly scheduled ;
basis such that vendor performance was reviewed as :
required by the QA program. The NRC inspector reviewed ,
the audit schedule for 1987 and verified that the vendors i that required a triennial audit were scheduled. The NRC I inspector reviewed the audit results for four vendors to l verify that the audit was performed when schedule A review of the audit schedule for 1988 was performed to verify that the triennial audit for the appropriate vendors had been schedule The NRC inspector also reviewed the documentation related to the vendor annual evaluation performed by the applicant. The established QA program requires an annual evaluation be performed in j
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the years when a triennial audit was not performed. The NRC inspector verified that the applicant was completing the annual evaluation f. Audit Program This QA program element was reviewed to verify that an adequate audit program had been established by the applicant. The items revi-wed within this area are discussed belo The audit program has been established by the QA program and is being implemented in accordance with the QA program requirements. The NRC inspector reviewed procedures issued for implementation of the audit program. Review of the procedures indicated that the audit program had been established in accordance with the requirements of the QA program. The NRC inspector reviewed documentation of seven audits to verify that the audit program was being performed in accordance with the implementing procedures.
i Audits were being performed by qualified individual The NRC inspector reviewed the qualifications for personnel performing the seven audits inspecte The review was performed to verify that each auditor had received the established training and that the individual's background was appropriate for the audit :
being performed. During review of this item, the NRC !
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inspector noted that Audit TUG-87-17, "Inservice l Inspection," dated August 21, 1987, was performed by ir.dividuals that did not appear to have strong technical expertise in the area of inservice inspectio The NRC inspector performed an in-depth review of Audit l TUG-87-17. Based on the review, it appeared that an adequate audit had been performed by the auditors l
assigne The applicant recognized the need to maintain technical l expertise within the audit group. To upgrade the l technical expertise in the audit group, the applicant i
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commenced staffing the group in September 1987 with personnel having technical expertise in the areas of emergency planning, licensed operations, health physics, inservice inspection, and radiological waste activitie Staffing of the audit group with personnel of this type was viewed by the NRC inspector as a positive move toward assuring that audits were performed by experienced auditors with proper technical backgrounds.
l An audit schedule was issued for each audit period that l included all areas required by the QA program. The NRC inspector reviewed the audit schedules for 1987 and 198 _ _ _ - _ - _ _ _ - _ _ _ - _ _
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The schedules included all areas required by the QA program. A review of the 1987 schedule was performed to verify that the audits were performed as scheduled. The review indicated that all audits were completed except those related to plant operation some audits were rescheduled during the years however, the audits were completed such that audit performance met the established frequency for each QA activit Audits performed by the applicant were performed in accordance with the QA program requirements. The NRC inspector reviewed seven audits performed during 1987 to !
verify that the audits were adequate. Based on the l review performed, it appeared the audits were done i properly in that a preapproved checklist was used, the ;
audit depth and scope was satisfactory, audit results l were discussed with the audited organization, i I
deficiencies and/or observations were appropriately identified, audit reports were issued in a timely manner, ,
adequate deficiency responses were provided by the 1 audited organization, and the deficiency responses I roccived timely review and close out by the audit organizatio j Based on the reviews performed, as discussed above, it appeared that the applicant had established and l implemented an adequate audit progra !
g. conclusions '
l Based on the review of the elements of the QA program, as discussed above, the inspector concluded that the applicant had established and implemented a comprehensive QA program. The procedures issued for program implemente. tion clearly defined the organizational responsibilities and provided specific guidance on how l the responsibilities were to be performed. With the exception of the one violation identified during this inspection, it appeared, based on the sample reviewed, j that the organizations were adequately implementing the procedural requirements during the performance of safety-related activitie Based on an overall review of the QA program, it appeared that the applicant relied on the performance of audits by the internal audit group to assure that safety-related activities were performed in l accordance with procedures. Since the applicant has established a strong audit organization with strong technical expertise, deficiencies in the QA program should be readily identified, and based on recent performance, should be corrected in a timely manne l l
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7. Plant Tours (92700)
The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to observe items such as house-keeping, equipment protection, and in-process work activitie Cable Spread Room - Structural Framework As reported in NRC Inspection Report 50-445/8732; 50-446/8724, the NRC inspector had identified instances of apparent improp-er bolted connections. During follow-up inspection an addi-tional concern arose regarding whether the structural frame-work, which supports most of the cable trays in the Unit 1 cable spread room, had been properly evaluated by engineerin The concern was resolved as follows. The applicant provided copies of the original drawings used to crect the structural framework. After reviewing the drawings, the NRC inspector determined that these drawings had provided sufficient detail for the construction and inspection of the original framewor For example, the drawings provided the size, type, location, orientation, and elevation of the columns and the cross members of the structur The drawings also provided the details for the bolted connec-tion In 1982 and subsequent to the completion of the framework, a set of as-built drawings detailing the framework and attachments was compiled by engineering. The as-built drawings are referred to as FSEG as-built Unit 1, Sheets 1-8 These FSEG drawings list the attachments and the loads for each of the crossbeams and columns and, hence, the FSEG drawings were utilized by SWEC as the basis for compiling a computer model of the framework to determine its integrity under load. Modifications to the loads, such as those occur-ring out of the CAP are included in the computer mode In addition to performing the evaluation of the framework, SWEC is in the process of issuing a new set of drawings for the Unit 1 cable spread room framework. The new drawings will incorporate the recent modifications and will be issued in the current format required by engineering. To preclude the possibility of changes by other contractors affecting the SWEC evaluation, all modifications to the framework must be I approved and evaluated by SWE !
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The NRC inspector did not perform an evaluation of the adequa- )
cy of the SWEC activity as the intent of the inspector's l review was to establish that an engineering evaluation of the Unit 1 cable spread room framework had been performed and that it included or accounted for recent modifications. The NRC 1 inspector considers that concern as being properly addresse )
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No violations or deviations were note No further NRC inspection is planned, i
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8. Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. One open item disclosed during this inspection is discussed in paragraph . Exit Interview (30703)
On January 29, 1988, R. F. Warnick, H. H. Livermore and J. S. Wiebe met with L. D. Nace and A. B. Scott to discuss January inspection findings and other matter (See NRC Inspection Report 50-445/88-06, paragraph 5.)
An exit interview was conducted February 2, 1988, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by the inspectors during this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio During this interview, the NRC inspectors summarized the scope and findings of the inspectio The applicant acknowledged the finding __-_ _ _ _ _ _ _ _ _ _ _ _ - - _