IR 05000445/1988069

Resident Safety Insp Repts 50-445/88-69 & 50-446/88-65 on 881005-1101.No Violations,Deviations or Unresolved Items Identified.Major Areas Inspected:Applicant Action on Previous Insp Findings & Control of Const Travelers

ML20206C192
Person / Time
Site:	Comanche Peak
Issue date:	11/10/1988
From:	Hale C, Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20206C188	List: IR 05000445/1988069 ML20206C187
References
50-445-88-69, 50-446-88-65, NUDOCS 8811160151
Download: ML20206C192 (8)

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. t U. S. NUCLEAR REGULATORY COMMISSION  :

OFFZCE OF SPECIAL PROJECTS l

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NRC Inspection Report: 50-445/88-69 Permits: CPPR-126 r 50-446/88-65- CPPR-127 l t

Dockets: 50-445 Category: A2 !

50-446 Construction Permit f Expiration Dates Unit 1: Extension request submitted

< Unit 2: Extension request ;

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submitte p 1 +

Applicant: TU Electric l Skyway Tower  !

i 400 North Olive Street  :

Lock Box 81  !

Dallas, Texas 75201 i Facility Name Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 >

Inspectior,Act Comanche Peak Site, Glen Rose, Texas [

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t a Inspection conducted: October 5 through November 1, 1988 [

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i Inspector nqr O , is/ ides >

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C. J. hule, Reactor Inspector (Date I

consultant J. Birmingham, Parameter (paragraphs 4 and 5) ,

i l Reviewed by: Edk/(A 'c" hCate'

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H'. H. Livermore, Lead Senior Inspector j i i

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Inspection Summary:

Inspection Conducted: October 5 through November 1, 1988 (Report 50-445/88-69: 50-446/88-65)

Areas Inspected: Unannounced, resident safety inspection of applicant actions on previous inspection findings, follow-up on violatiens/doviations, control of construction travelers, inspected item removal noticos, FSAR Amendment 74, and applicant's mooting Results: Within the areas inspected, no violations, deviations, or unresolved items were identified. A procedural change requiring the use of construction travelers for TO Electric construction work packages (CWP) strengthened the program and is discussed in paragraph ,

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( 3 DETAILS Persons contacted

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• R. W. Ackley, Jr., Director, CECO

• R. P. Baker, Licensing Compliance hanagor, TU Electric

• J. L. Barker, Manager, Engineering Assurar9c, TU Electric

• D. P. Barry, Manager, ESG, SWEC

• J. Beck, Vice President, Nuclear Engineering, TU Electric ,

• M. Blevins, Manager, Technical Support, TU Electric

• H. Bruner, Senior Vice President, TU Electric

• W. Cahill, Consultant, TU Electric

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• J. Conly, APE-Licensing, SWEC

• G. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• R. D. Delano, Licensing Engineer, TV Electric t *D. E. Devincy, Deputy Director, Quality Assuranco (QA),

TV Electric l *G. L. Edgar, Attorney, Newman and Holtzinger

• G. E. Grabruck, QA, Impoll

• W. G. Guldemond, Executive Assistant, TU Electric

• P. E. Halstead, Manager, Quality Contro) (OC), TU Electric

• T. L. Heatherly, Licensing Complianco Engineer, TU Electric

• C. B. Hogg, Engineering Manager, Bochtel

• R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

• J. J. Kelloy, Manager, Plant Operations, TU Electric

• 0. W. Lowe, Director of Engineering, TU Electric

• F. W. Madden, Mechanical Engineering Manager, TU Electric

• G. M. McGrath, TS/SP Manager, Startup, TU Electric

• J. C. Miller, Site Managor, TENERA

• J. W. Muffett, Manager of Civil Engineering, TU Electric

• L. D. Nace, Vice President, Engineering & Construction, TU El :tric

• E. F. Ottney, Representative, CASE

• S. S. Palmer, Project Manager, TU Electric

• J. D. Redding, Executive Assistant, TU Electric

• D. M. Reyncrson, Director of Construction, TU Electric

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric

• P. B. Stevens, Manager, Electrical Engineering, TU Electric

• J. F. Strcctor, Director, QA, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric

• T. G. Tyler, Director of Projects, TU Electric

• J. R. Waters, Licensing Compliance E..gineer, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the November 1, 1988, exit meetin _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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4 Applicant Action on Previous inspection Findinos (92701)

(Closed) Open Item (445/8810-0-07; 446/8808-o-07,1 The FSAR did not accurately describe the permanent onsite records storage facilit In early 1988, the FSAR identified the Permanent Plant Records i

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Vault (PPRV) as the onsite records storage facility even though three other facilitics were being used for that purpos Amendment 71 to the FSAR dated May 27, 1988, doloted the reference to the PPRV, but failed to identify the records l storage facilitics being used. On October 14, 1988, Amendmont 74 to the FSAR was submitted which identified the Operation ,

Record Center, Engineering Records Center, and Project Records l Center as the record storage facilitics designed, constructed, and maintained in accordance with applicabic requirement This action closes this open ite ;

I Follow-up on Violations / Deviations (92702) ,

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(Closed) Violation (445/8801-V-02; 446/8801-V-02): The  !

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j technical content of inspection Proceduro NQA 3.09-5.01 was

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1 changed by Design Change Notico (DCN)-3 without prior review

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and approval of the discipline Level III inspecto l

) The applicant has agreed with the stated violation. To j

resolve the issue, TU Electric issued deviation report

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i (DR)-88-00591 to identify those DCNs which were implemented without the required Level III review and approval. These DCNs were subsequently reviewed by the appropriate discipline  !

l Level III inspector and, if determined adequate, were approved by the Level III inspector. None were found inadequate by the '

i Lovel III. Additionally, Procedure NQA 1.03, Development, Revision, Control and Distribution of TU Electric NEO Quality

Assurance Department Procedure, Revision 4, was revised to  ;

clarify the need for appropriate Level III review and approval i of DCNs. DCN-3 to NQA 1.03, Revision 4, provided a matrix of l l those procedures whose content was of a technical rather than c administrative nature and therefore required approval by the  ;

discipline Level II I

The NRC inspector reviewed the above actions and the i documentation resulting from the review of previously issued l i

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DCNs. The NRC inspector determined that the review of

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procedures to identify DCNs issued wit.aut Lovel III review  ;

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and approval was complete and that the subsequent review and ,

approval of the identified DCNs was prope ;

i Based on the above actions, this violation is close [

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5 Control of Construction Travelers (35061)

During this report period, the NRC inspector reviewed the current procedures used at the CPSES to control construction work performed to travelers. Two systems exist for the generation and use of travolors. One system is used to control work activitics related to ASME installation prior to being turned over to the owr.c The other system is used to control work activitics on non-ASME safety-related equipment, balance-of-plant, and ASME items turned over to the applican Procedures reviewed were:

. ECC 2.33-4, "Construction Work Package Generation,"

Revision 2

. ECC 2.13-5, "Construction Traveler," Revision 4

. ECC 2.13-5A, "Construction Traveler Generation,"

Revision 2

. STA-806, "Construction Work Requests and Work Orders,"

Revision 12

. CP-SAP-6, "Control of Work on Station Components After Release from Construction," Revision 14

. ACP-10.1, "Preparation, Approval and Control of Construction Operation Travelers," Revision 1

. ACP-10.2, "Inspected Item Removal Notico Form,"

Revision 1

. ACP-10.4, "Documentation for ASME Wolding, Fabritttion and Installation Activitics," Revision 4

. AAP-7.2, "Package Flow Control," Revision 2

. AAP-7.3, "Document Package Preparation," Revision 1

. CPE-TD-BR-065, "Fabrication and Installation of ASME Sectjon III Division I Systems and Associated Non-ASME Items," Revision 1

. CPE-TD-BR-066, "ASME Section XI Repair Replacement and Modification," Revision 2 During the review the NRC inspector assessed specific issues related to traveler use that had been identified in previous NRC inspection reports. For exampic, the NRC inspector noted that Procedure AAP-7.3, which controls document package preparation for ASME related work, did not require that a traveler always be issued to control construction wor This

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condition was al.lowable if the applicable documents in the i

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documentation package provided sufficient direction to control the work and assure proper QC inspection. The NRC inspector reviewed the documents used for those activitics (e.g.,

Multiple Wold Data Cards and Wold Data Cards) and Procedure ACP 10.4, which provides the details for their us The NRC inspector determined that, if the documentation

package was properly prepared, sufficient direction would be given to control construction work. Other areas reviewed l included: proper use of Inspected Item Removal Notices !'

(IRNs): review and approval by tne Authorized Nuclear Inspector (ANI); proper processing of revisions to assure that .

travelers are updated when the applicabic controlled documents l are revised; and proper control of the issuance, distributic a, and voiding (if applicabic) of travelers.

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The NRC inspector's review determined that adequate curro procedures exist to control the preparation, review, approval,

, and utilization of construction travelers both for ASME r.n3 2 non-ASME related wor I No violations or deviations were identifie l 5. Inspected Item Removal Notico (35061)

Recent changes in sito procedures controlling the use of IRNs prornpted the NRC inspector to review those procedurc [

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i historically, IRNs have been used at CPSES by Brown and Root ,

j (B&R) for ASME related work and by TU Electric for non-ASME [

wor Th2 intent of IRNs was to allow craft to notify

construction management of the need to remove or disassemble '

a an item or component that had been inspected by Q After !

l approval by construction management, the IRN was to be routed ;

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through the Paper Flow Group for preparation of a i

documentation package and the inclusion of any required

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inspection points, whether by QC or the AN r i The documentation package did not always require that a j construction traveler (a detailed, stop by step, description

of the work to be performed) be prepared and include In j 1 addition to the procedures identified in paragraph 3. above, the NRC inspector reviewed Procedure CP-CPM-6.10, "Inspected j

Item Removal Notico Form," now delete ,

i From this review, the NRC inspector determined that the use of IRNs by TU Electric for non-ASME, balanco-of-plant, and ASME l

Section XI work had been discontinued. Section 6.11.1.1 of ECC 2.13-5 provided guidelines for a controlled phascout of

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IRN The NRC inspector also dotormined that IRNs are i continuing to be used by B&R fcr ASME Section III related l I wor B&R Procedure ACP 10.2 provided the guidance for the [

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i use and control of IRNs by B&R. The NRC inspector notes that dolction of the use of IRNs by TU Electric was accompanied by a requirement that a construction traveler be issued for each

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construction work package (CWP) that required physical work to be performed. The inclusion of a construction travelor in the CW9 provided control of construction work and increased the assurance that QC inspection points would not be misse I i

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The continued use of the IRN by B&R for ASME Section III work appears acceptable due to the use of other detailed documents such as those required by B&R proceduro ACP 1 "Documentation for ASME Wolding, Fabrication and Installation ,

Activitics." '

i The NRC inspector concluded from this procedural review that use of IRNs is adoquately controlled. NRC inspection of tho ,

i implementation of those procedures will be performed as part I

of the normal NRC review and inspection of sito activitic No violations or deviations woro identified. The use of j construction travelors in the TU Electric CWP appears to ;

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strengthen the program by providing increased control of construction and inspection activitics. The continued use of .

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IRNs for the B&R work packages appears to be effectively described and co.rtrolled by Procedure ACP 1 ; Inspection of FSAR knendment 74 (350F1) l

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The NRC inspector revicwed the changes to the QA program i described in FSAR Amendment 74 dated October 14, 198 The '

primary purpose of the changes in this amendment was to

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reflect the QA organi:ation changes that occurred in [

July 1988. No reduction in QA program commitments werc !

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] Applicant's Meetings (92700) J i  :

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1 The NRC inspector frequently attended applicant's mootings concerning site activitics and implementation of various sito programs. Moctings attended during this reporting period included:

QA Overview Committee Mcoting

) Quality Documentation Review Workshop

Chango Control Board J

j While those mootings reflect managament's involvement in

! day-to-day activitics and attention to potential problems, no violations or deviations were ideatified and no items of significance were noted.

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' - t 8. Exit Meeting (30703)

An exit mcoting was conducted on November 1, 1988, with the applicant's representatives identified in paragraph 1 of this repor No written material was provided to the applicant by the inspector during this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. During this meeting, the NRC inspector summarized the scopo and findings of the inspection.

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