IR 05000445/1988085

Initial SALP Repts 50-445/88-85 & 50-446/88-81 for Sept 1988 - Aug 1989

ML20006D947
Person / Time
Site:	Comanche Peak
Issue date:	08/31/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20006D940	List: IR 05000445/1988085 ML20006D939
References
50-445-88-85, 50-446-88-81, NUDOCS 9002150290
Download: ML20006D947 (29)

Text

. - - -

--

y

,

,

s.

5 --

!

!

,

i

.

,

'

i

.

INITIAL SALP REPORT

,

!

!

I

.

..

.....................

...

......

.......

!

i I

U.S. NUCLEAR REGULATORY COMMISSION

,

0FFICE OF NUCLEAR REACTOR REGULATION

-

!

COMANCHE PEAK PROJECT DIVISION

!

i

'

.

.

.

.....

-.

.

...............

......

i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

)

,

Inspection Report 50-445/88-85 - 50-446/88-81 i

,

Texas Utilities Electric Company (TV Electric)

j

Comanche Peak Steam Electric Station i

Dockets 50-445; 50-446 - Units 1 and 2 i

!

September 1, 1988 - August 31, 1989

.

.

!

.

.

.

.9002150290 900205 rh PDR ADOCK 05000445

Gt PDC

,..

-

_

-

.

_

.-

-

.

._.

-.

.. -

...

s

.

..

s-1-I.

INTRODUCTION TheSystematicAssessmentofLicenseePerformance(SALP)programisan integrated NRC staff effort to collect available observations and data on i

a periodic basis and to evaluate applicant performance on the basis of this information. 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 provide meaningful feedback to the applicant's management 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

.

September 19 to review the observations and data on performance and to assess applicant performance in accordance with NRC Manual Chapter 0516

" Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this report. The Board's findings and recommendations were forwarded to the NRC Associate Director for Special Projects, Office of Nuclear Reactor Regulation, for approval and issuance.

This report is the NRC's assessment of the applicant's safety performance at Comanche Peak for the period September 1, 1988, through August 31, 1989.

(.

The SALP Board for Comanche peak was composed of:

Chairman: C. I. Grimes, Director, Comanche Peak Project Division

'

Members:

T. P. Gwynn, Deputy Director,- Division of Reactor Projects.

• Region IV J. P. Jaudon, Deputy Director, Division of Reactor Safety, Region IV H. H. Livermore, Lead Senior Inspector, l

Comanche Peak Project Division J. E. Lyons, Assistant Director for Technical Programs, Comanche Peak Project Division P.F.McKee,(Chief,SafeguardsBranch.OfficeofNuclearReactor Regulation Former Deputy Director, Comanche Peak Project l

Division),

,

R. F. Warnick, Assistant Director for Inspection Programs,

'

Comanche Peak Project Division J. S. Wiebe, Senior Project Inspector, l-Comanche Peak Project Division i

.

,

- -, >

-..

_--

.

-.

._..

-

- -.

_ - - - -.

...

..

,

,

[

\\

,

.

t i

}

,

J. H. Wilson, Assistant Director for Projects, Comanche Peak Project Division l

L. A. Yandell, Deputy Director, Division of Radiation Safety and Safeguards, Region IV l

!

The following personnel also participated in the SALP Board process.

.

J. L. Birmingham, RTS Consultant (Quality Control),

Comanche Peak Project Division j

S. D. Bitter, Resident inspector (Operations),

Comanche Peak Project Division

S. P. Burris, Senior Resident Inspector Watts Barr, TVA Projects Division (former Senior Resident Inspector, Comanche Peak Project Division)

R.M.Latta,ResidentInspector(Electrical).

Comanche Peak Project Division W. D. Richins, Parameter Consultant (Civil

!'

Structural), Comanche Peak Project Division M. F. Runyan, Resident inspector (Civil Structural),

-

Comanche Peak Project Division P. Stanish, Parameter Consultant (Mechanical),

Comanche Peak Project Division

.

R. G. Ramirez Human Factors Specialist (Attended Only)

',

Division of Licensee Performance and Quality Evaluation

<

II. Sunmar.y of.Results Dverview Applicantmanagement'sinvolvementandcontrolareevidentbyleadershipIes.

support, and monitoring of completion of construction and rework activit L

A weakness was noted in management's involvement and control of the L

identification and reso.lution of technical issues related to operational

-

events during the Hot Functional Test (HFT). Since the HFT, management'

L

'

has demonstrated increased sensitivity in this area. The applicant's'

approach to the identification and resolution of technical issues is

adequate, but occasionally lacks conservatism, thoroughness, and depth.

Applicant management is usually responsive to NRC initiatives and self-identified concerns.

However, occasionally the responses do not address fully the generic implications and root causes.

As a result,' considerable NRC effort, at the working level, is required to obtain acceptable resolu-tions. Major violations are rare and minor violations are usually not L

L

.

.

'

.

.

_ _ _ _

_

_.. _ _

_

_ _.. __

!

..

$

.

.

'

-3-

.

l i

repetitive or indicative of programmatic breakdown.

In general, the number of violations are very small when contrasted with the large amount of NRC direct inspection effort. The applicant's nuclear management staff i

has considerable experience and their attitude toward the NRC regulations, safety issues, and concerns raised by employees is generally very good.

The applicant's training programs are generally very good. The maintenance i

training facility is especially impressive and has the potential to provide

the basis for an excellent maintenance organization. The performance of

i operators on the NRC administered requalification examination was out-standing and indicates that the applicant has improved the training program as reconsnended by the previous SALP assessment (50-445/87-40; 50-446/87-31).

!

i A suninary of the applicant's performance in each functional area is given below along with the performance from the previous SALP assessment.

,

Functional Performance Performance Performance l

3yria Categor.y catecon Trend *

l 9/1/87-8/31/88 9/1/88 8/31/89 Construction & Corrective Action Programs **-

None l

i

!

Cont, maj.struct.& supports

Piping sys. & supports

'

Auxiliary sys.

Elec. equip. A cables

l-Eng. & Technical Support

2 None Safety Asses, & Quality Ver.

2 None Plant Operation

2 None

!

Maint. & Surveillance NR

None i

Security

2 None

.

Radiological Controls NR

None l

Emergency Preparedness

2 None

]

.

.

NOTE: NR =,Not Rated

• Performance Trend: Any discernible trend in the applicant's performance throughout the assessment period which is determined to be indicative of the

applicant's expected performance during the first few months of the next assessment period.

It is reserved for those instances when it is necessary

,

i

!

to focus NRC and applicant attention on an area with a declining performance

.. trend, or to acknowledge an improving trend in performance.

• • This functional area was evaluated in the last SALP rep (ort period (9/1/87-8/31/88) as four separate areas.

In this SALP period 9/1/88-8/31/89) this.

,

L

'

functional area includes the four areas evaluated in the last SALP along with all other aspects of the construction and corrective acti.on programs.

• ,

t

-

-

-

-

-

- - -

.

-.

- -

- - - - - -

-

-

.

- -

- - - - -

- - - - -

-... - - -.. -.

.,

,

~

e

-

-

.

._..

_ _ _

._.

__

._- _. _

_

_ _

,

f 4.

t

,-

,

,

-4

.

!

-III. Criteria

'

Applicant performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase.

i Functional areas normally represent areas significant to nuclear safety

-

and the environment. Some functional areas may not be assessed because i

- of little or no applicant activities or lack of meaningful NRC observations.

Special areas may se added to highlight significant observations.

i The following evaluation criteria were used, as applicable, to assess each functional area:

I Assurance of quality, including management involvenent and control;

.

Approach to the resolution of technical issues from a safety

.

standpoint; Responsiveness to NRC initiatives;

.

,

Enforcement history;

.

Operational and construction events (including response to, analyses

.

of, reporting of, and corrective actions for);

Staffing (includingmanagement);and

.

Effectiveness of training and qualification program.

.

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 according to three performance categories. The definitions of these

performance categories are as follows:

,

A.

Category.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 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 are good. The applicant has attained a level of performance above that needed to meet

-

.- -

_

-.-

-

--

.

-

.

.,

_

.

_

_

.

_. _

. _ _ _

. _

_. _

_ _ _

.

'

.

.

.

.

-5-l

!

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 leveis.

l C.

Category. 3 r

Applicant management attention to and involvement in the performance

of nuclear safety or safeguards activities are not sufficient. The applicant's performance does not significantly exceed that needed to i

meet minimal regulatory requirements. Applicant resources appear to j

be strained or not effectively used. NRC attention should be increased above normal levels.

IV.

Performance. Analysis A.

Construction and. corrective Action. Programs

1.

Analyses This functional area includes all applicant activities associated

.

with the erection of structures and the installation of those i

systems and equipment required for the operation of the Comanche Peak plant. Further, it addresses the compliance of those

'

and activities with design specifications, industry standards,fforts regulatory requirements. The majority of NRC inspection e

,

'

in this functional area involved the evaluation of TV Electric's Corrective Action Program (CAP), including the Post-Construction Hardware Validation.Proaram (PCHVP) as well as completion of

l the construction program. The CAP is the applicant initiated program to address and resolve specific Comanche Peak Response Team (CPRT) and other external source ~1ssues.

The PCHVP is the L

portion of the CAP which validates the final acceptance l

attributes for safety-related hardware. The NRC assessment of this functional area included the inspection of electrical equipment, cables, instrumentation, mechanical components, t

piping and pipe supports, heating, ventilation and air-conditioning (HVAC), structural steel, concrete structures, and other safety-related items.

Fifty NRC inspections of construction and CAP activities, L

including three team inspections, determined that construction

'

activities were generally well performed with adequate docu-mentation and an appropriate involvement of quality control.

,

'

Examples of well performed construction activities witnessed or inspected by the NRC staff inspectors included concrete repair

,

and placement activities related to the seismic gap between primary and secondary building walls, replacement of structural steel bolts, and base plate installation. However, occasional minor programmatic breakdowns did occur.

For example, a pipe support angularity problem identified by the NRC necessitated a r

.

e

>

-

-

_

__

.

-

-

-

- - - - - -.

.__-... -

..-.--.

_.-

.-

i

.

.

!

.-

.

!

'

'

-6-

!

!

reinspection by the applicant of over 5,000 pipe supports and

?

resulted in significent rework.

'

Management involvement in assuring quality for these areas was

generally evidenced by prior planning and assignment of priori-ties in all areas reviewed. Procedures for the control of

activities were stated and defined. However some deficiencies

werenotedinproceduresforstructuralstee$platforminspection,

'

seal welding, and check valve backleakage testing that required

'

revision to address NRC idantified concerns. Management involve-ment was also evident during frequent status meetings with NRC r

inspectors to provide updates regarding proposed or ongoing

plant activities. One example of management involvement was the

-

.

effective corrective actions taken to address deficiencies in

,

concrete attachment spacing.

In general, engineering evaluations were determined to be technically adequate and complete during team inspections of the CAP. Within the electrical area, the increased emphasis on identifying the root cause of deficiencies and establishing

,

adequate corrective action indicated an improved management

'

commitment to quality. As discussed in Section IV.B of this report, there were problems with the effectiveness of engineering

.

and technical support which affected the construction and

,

Corrective Action Programs.

In addition, some design change

!

'

authorizations (DCA) and nonconformance reports in the civil /

i structural area initially had inadequate technical evaluations.

I-L Corrective actions were implemented by the applicant and

'

L evaluated by the NRC.

Records of construction activities were generally complete and

,

adequately maintained; however, in some cases, the retrievability of records could be improved.

Recurring problems of unrepaired damage or unauthorized work resulted in the applicant placing heavy reliance on performing room and area walkdowns to-identify remaining deficiencies prior

.'

to turnover to operations. An NRC inspection performed late in the SALP period of two rooms for which the walkdown was complete,

.

identifiedseveraldeficiencIesintheelectricalconduit installations as well as two potential mechanical snubber

,

problems which had not been identified by the applicant.

In

-

QC inspection errors during the evaluation of addition,l steel under the CAP program were identified in structura several NRC inspection reports before action was taken by the l

I applicant to evaluate and resolve the concern. The NRC is continuing to evaluate the applicant's corrective action.

'

The applicant's resolutions of technical is'ues including s

'

self-identified deficiencies were generally determined to be

'

,

l l

.-

-

.

...

-

-.

--

._.

- -.,.

.-

-.

- - - -...

-.,

r

.

.

.

.

h

-

,-7-b

!

effective. Typically, the applicant used worst-case or con-

,

servative assumptions when precise loads or conditions could not l

be determined.

In a few instances such as the piping support slugged weld / weld fit-up problem it was necessary for the

!

NRCtocauseadditionalengineerIngiterationsbeforean

adequate resolution of the full technical issue was demonstratec.

Resolutions of NRC concerns were generally satisfactory but

,

occasionally lacking in thoroughness or depth, such that supple-

!

mentary responses were required. The applicant was occasionally

slow to address fully the generic implications and/or root l

causes of NRC concerns. This was evident by the applicant's

responses to violations for problems with QC inspections of l

structural steel platforms, QC measurement techniques, service

water tube steel supports, and undersized welds on duct supports.

i Repeated meetings between the NRC and the applicant's represen-tatives were required before acceptable resolutions to these

,

issues were achieved.

The NRC inspections identified several violations involving QC

.

-

inspection errors; however, these errors appear to have been l'

l isolated cases. Other deficiencies identified wer1r for )ro-

,

grammatic problems such as, field verification methods (:VMs)

f ailing to provide sufficient instruction for verification of inaccessible attributes and QC measurement techniques being inadequate to correctly identify valve stem angles. These

'

issues have been or are being satisfactorily resolved.

i Staffing is' adequate as evidenced by the majority'of construction l'

activities remaining essentially-on schedule.

Key management positions are staffed with competent individuals, and the responsibilities of each position are defined.

.

The applicant's training program for construction related

,

'

activities appeared to be effective. An active training program for craft and technical personnel was maintained by the appitcant.

During the assessment period, several training classes were evaluated including those conducted for flexible conduit l

installation, nondestructive examination training provided to QC l-personnel, and the training associated with the Unit 2 service l

water coating removal effort. These training sessions were judged to be effective and thorough.

In isolated instances, l

training deficiencies were identified as the root cause of specific problems.

2.

Performance Rating

.

The applicant's rating is performance Category 2 in this area.

,

,

,

_,

_

. _ _ _ _ _.___

_

_. _ _

. _ __

_..

_

_

l c

.

.

.

,

-8-l

.

,

!

{

3.

Board Recommendations a.

Recommended.NRC.Actica j

None.

t b.

Recommended Applicant. Action l

The applicant should review the control of documents

.

to determine methods to improve their retrieval tine.

i Management should place additional attention on the

'

.

room and area turnover process to assure the identi-fication of remaining deficiencies.

]

8.

Engineerino and. Technical. Support 1.

Analysis The purpose of this functional area is to address the adequacy

!

of the technical and engineering support for all plant activities.

It includes all applicant activities associated with the design

-

of the plant; engineering and technical support for maintenance,

-

testing, surveillance, procurement, preoperational and startup

testing, and operational activities; training; and configuration

'

management (including maintaining design bases and safety margins).

NRC reviews of engineering and technical support activities

,'

occurred during perfomance of NRC inspections of construction /

CAP, preoperational testing, and during review of-FSAR submittals.

The engineering and technical support activities were generally

,

performed well.

Examples are the core reload analysis, the TDI

'

L diesel generator evaluation, numerous responses to staff requests -

!

for additional information, and equipir.ent qualification work.

,

This generally good performance was also evident by the favorable l

results of the pump and valve operability review team inspection, the seismic qualification review team inspection, and three team L-inspections of the corrective action program which included

,

review of significant engineering work. However, some

-

I engineering evaluations of construction deficiencies and events

"

and some responses to NRC initiatives were lacking in thorough-ness and depth.

Examples included the failure to adequately

' disposition the deficiencies in the fuel transfer tube pene-u

'

tration weld ar.d the failure to adequately disposition the lack of NDE on electrical penetrations.

Corporate management was frequently involved in site activities

'

,

as evidenced by actions showing their interest in and knowledge of technical concerns and their resolution.

.

F

_ _.....

..

.. _ _.

.- _

,

._

-

_ _. -

-

-

-. -. -

_.

- _ ___..

-,

l

)

,

.

j

.

a l

.

9-j

-

l During the rating wriod, the applicant submmd a large number of amendments to tie FSAR and responded to a my large number

of information requests associated with the NRC's review of that document. For the most part, these submittals and responses i

were clear, timely, and supported by sound technical justifica-j tion. However, in the areas of technical specification develop-i ment and the review of the preoperational testing program,

.

considerable effort was expended by the staff to assure that an

adequate technical basis was formally placed on the docket.

{

The NRC identified three violations that were programmatic in nature and two violations that appeared to be isolated occurrences.

allowedtheuseoflow-strengthbolting(A-307)ginappropriately The programmatic violations included: engineerin in snubbers; design reviews failed to identify and correct numerous minor deficiencies found in pipe support calculations; and the applicant inappropriately accepted certain welds based on stress analyses provided by engineering in lieu of required non.

destructive examinations. Appropriate corrective actions were subsequently taken for these issues.

Two apparent violations for improper evaluation of deficiencies and lack of post maintenance testing for certain auxiliary feedwater (AFW) check valves were identified as a result of 'the

,

findingsofanNRCAugmentedInspectionTeam(AIT)andatthe close of the assessment period were pending as an enforcement

,

issue. The AIT findings are discussed further in Section IV.D,

" Plant Operations."

'

q The quality and responsiveness of the technical support provioed in response to the AFW check valve event (ciscussed in Section

IV.D) were marginal during the initial phases of the applicant's t

investigation.

Information exchanged within the AFW task team was often unfocused, misleading, and inaccurate. This resulted

,

in considerable delay in identifying the failure mode of the

'

check valves and in preparing a plan for corrective action.

.

Improvement in the technical support function was clearly evidentfollowingareorganizationofthetaskteamanda redefinition of the team s objectives. As a result, an e ffective corrective plan was ultimately achieved.

The applicant has implemented an effective configuration control prograr with accurate baseline information and reliable methods

for making necessary changes. Only a few minor discrepancies have been identified regarding this program, such as a valve stem that was rotated and left out of angular specification as the result of a seal weld application.

Programmatic enhancements have been made to address the identiffed problems.

In the area of procurement, the applicant had revised the procedural program for procurement to provide increased

-

.

.

&

i

-

__

,_,..,,_.v

.,,,_,.u.

_. _., _

_ _

.%.,

,'

~-,y

~

,

.

-

q

,

.

,

!

,

.

.

- 10 -

"

accountability and assurance that safety-related services, parts and equipment were of the desired quality. However, evaluations of some events, such as the removal of the Plasite coating from the Service Water System (SWS) piping and the installation of valve internals which were-procured as nonsafety related into AFW control valv6 FC-121, indicated the need for i

improvements to the procurement process. Corrective actions

!

were being implemented at the end of the assessment period.

Staffing levels for engineering and technical support organizations-are ample, although ;nany of the individuals are contractors.

Positions and responsibilities for the technical support of operations, preoperational testing, and startup testing are well-defined. During NRC inspections, the qualifications and training of engineering and support personnel were inspected and

,

determined to be satisfactory. NRC inspecticos of engineering

!

and technical input to the CAP and preoperational testing identified isolated instances where inadequate training was-determined to be a cause. When these instances were identified, the applicant took appropriate actions to correct the deficien-cies. The NRC. concluded that overall training activities were i

satisf actory.

The training and qualification program for preoperational and startup testing personnel is adequate. The applicant's licensed operator train < ng program has been significantly improved since the last SALP rating period. This was evidenced by a 100% pass rate for the NRC administered reoualification examination. The training staff is composed of qualified individuals possessing the necessary skills and expertise. Applicant management dis) layed a willingness and desire'to establish and maintain a hig11y-motivated training organization.

2.

Performance. Rating The applicant's rating is performanca Category 2 in this area.

3.

Board. Recommendation _s a.

Recommended.NRC Action None,

_,

b.

Recommended. Applicant. Action The applicant should take action to ensure adequate engineering and technical support for operations exists in order to resolve technical issues such as the AFW check valve failures. Of particular importance is the thoroughness and depth of technical resolutions developed.

,

a

.

.

...

.

..

_

.

..,

.-

-

.

.. -

. - - - -..

. _

.. -.

,qce.

.

,,

> r

.

.

.

- 11 -

.

q

!

C.

Safety. Assessment and Ouality. Verification'

)

1.

Analysis

'

This. functional area includes all applicant review activities

']

q associated with the implementation of: applicant safety policies; exemption and relief applicant activities related to amendment H

requests;responsetogenericletters, bulletins,andinformation j.

l0 notices;-and it also includes applicant activities related to the resolution of safety issues,10 CFR 50.59 reviews 10 CFR 21 J

p assessments, safety comittee and.self-assessment activities.

l analyses' of industry's operational experience, root cause -

analyses of plant events, use of feedback from plant quality assurance and quality control reviews, and' participation in self-improvement programs.

It includes the effectiveness of the j

applicant's quality verification function in identifying and l

l

.

correcting substandard or anomalous performance, in identifying l

precursors of potential problems, and in monitoring the overall l

performance'of the plant.

l L-NRC personnel performed, inspection activities which resulted in

?

the issuance of 12 inspection reports of quality programs.

L Other NRC inspections provided perspective regarding the

-

adequacy of the applicant's performance of safety assessment and quality verification.

l L'

The staff determined that management involvement:in safety assessment and quality verification was apparent in,most

,

l activities. Evidence of this involvement was demonstrated by.

t-

-n.

management participation in the Senior QA Overview Committee and in management's' involvement.in the resolution of technical issues.. Additionally, staff. review of documents such as

.t4 applicant audits, corrective action reports (CARS), and SDARs indicated that items with' potential generic applicability were

'

addressed by appropriate management personnel.

r Evidence of prior )lanning and the assignment of priorities was -

apparent in the scledules for audits'and surveillances, the

.

H performance of preoperational tests, and the ccmpletion of L

construction activities.

-

.

('

Resolutions of deficiencies were, in general, adequate although occasional. repetitions of identified deficiencies indicated that

,

root ct ase assessments and corrective actions were not always effect've. An example of this was minor' design calculation errors found in the CAP. After the NRC identified the same problrm during inspections, held meetings with TV Electric manag ment, and issued a violation for the same issue, the i

L appl' cant'took adequate c.orrective actions.

L l

...

i.

t.

__

.

^~*-

~

,7

(-

g jyy

'

-

'

..

u i

...

-r12 -

L The applicant's program for the identification and correction of nonconforming or deficient conditions was effective. An example of an effective self-evaluation and correct,ve action resulted from audit TSU-89-01 in which the audit team utilized ongoing

activitiet of the HFT to perform real-time assessments of testing activities. The audit identified that the programs for-engineering, procurement, and testing failed to prevent unapproved, valve internals being installed as permanent plant equipment in flow control valve 1-FCV-121. The audit deficiency-resulted in management action in all of the affected departments..

The applicant has many self-evaluation organizations and programs.

These include the Quality Assurance Organization, the Quality j

Control' Group, the Station Operations Review Comittee (SORC),

the Operations Review Comittee (0RC), the Independent Safety EngineeringGroup)(ISEG),theJointTestGroup(JTG)[,theTest Review Group (TRG, the Technical Audit Program (TAP Engineering Functional Evaluations, Operations Readiness Assessment, Plant

,

L

<

- Evaluation Group, and Senior QA Overview Comittee. Generally,

'

these programs and organizations performed adequately. - Specific

'

i examples where they did not identify and correct deficiencies

!

are noted.in the specific functional areas of this report.

'

f The applicant's responsiveness to NRC Bulletins and Information i

Notices was' generally timely and thorough. Examples of this were responses to NRC Bulletin 88-10 (involving moldea case circuit breakers) and NRC Bulletin 88-01 (pertaining to ir.cp::ti:n:.cf. Westinghouse DS series circuit breakers used in L

Class IE applications).

,

In response to NRC Information Notice 88-89, " Degradation of j

-

Kapton Insulation," the applicant performed evaluations of the

'

site uses.of Kapton insulation. The evaluations determined that the primary area of concern was the potential that construction activity in the area may have-damaged the Kapton insulation.

The applicant initiated corrective actions including detailed inspection and cleaning of the insulation prior to the installation of protective cable tray covers. Although

incomplete at the end of the SALP period, the applicant's corrective actions were appropriately addressing the concerns identified by the information notice.

Three violations were identified:

(1)inadequateperformanceof preoperationaltestsurveillance,(2)inadequateinterpretation of a radiographic indication, and (3) a procedural change-i resulting in the failure to perform reportability evaluations for certain unsatisfactory QC inspection reports. These violations appeared to be isolated and not indicative of a L

programmatic problem.

-

/

i

.

_ -

_

. _ _. _ _ _

.

__

. _ _.. _

_

,

fc 3

.j

.+ 3 y

+

.

>

.

- 13 -

,

,

An NRC-assessment of the plant evaluation group indicated that o

the~ group was adequately structured and staffed to provide evaluation of plant operations and maintenance activities. The group is responsible for reviewing issues such as: industry operating experience reports, emerging regulatory issues, and'

site performance. The ultimate purpose is to identify precursors-to potential problems. The group has taken timely actions to l

address recent' industry issues such as mid-loop operations of i

the Reactor Coolant System (RCS) and the adequacy of instrument air systems.

The applicant's QA/QC was not always effective. For example, curing plant tours,.the NRC identified problems with 23 pipe j

supports previously accepted by the' applicant's QC.. Also,

_

during an inspection of the_ applicant's room / area turnover process, the NRC-identified several conduit fitting concerns even though both engineering and QA surveillance walkdowns of the rooms had been performed. QA/QC. management was not L.

always effective in directing their organizations to perform

,

in-depth inspections and to identify problems as they occurred..

Staffing in this functional area is appropriate. Qualifications of personnel meet requirements and, in general, a high degree of nuclear industry experience.is evident. Vacant key positions-l are filled in a reasonable amount of time. During this. assess-ment period, the applicant's quality accountability program j

.

reduced the overall percentage of deficient items resulting from construction activities.

Training and qualification programs have resulted in an under-standing and awareness of procedures and procedural requirements.

Training needs of staff positions are well-defined and imple--

l mented. ~ Training of personnel to new procedures or revisions is usually timely; however,' occasional recurrence of deficiencies has necessitated retraining of specific individuals or groups.

y Management response to identified needs for retraining is usually

-

,

! -

prompt and effective.

In general,-procedures and policies are

..

'

rarely violated.

2.

Performance. Rating The applicant's rating is Performance Category 2 in this area.

,

3.

Board Recommendations a.

Recommended,NRC Action

,

None,

,

I

I,

' i

.

i

.

.

m

~

.

. -

..

-

,

y'on

..:

..

,

,-.

L j

- 14 -

b.

Reconnended Applicant. Action Management should develop ways to improve the effectiveness of the QA/QC organizations in early problem identification.

D.

plant.0peration 1.

Analysis-This functional area-consists chiefly of the control and exe.

cution of activities directly related to operating plant systems, primarily preoperational testing and operational readiness activities. Llt is intended to include = activities such as system startup, shutdown, and lineups. Thus, it includes activities such as preoperational testing, monitoring and logging plant conditions, prerequisite test operations, response to off-normal.

conditions, plant-wide housekeeping, control room professionalism, and interface with activities that support operations.

NRC personnel performed inspections.resulting in 14 inspection reports of preoperational testing and operations-related activities. This included. team inspections of operational

. procedures and emergency operating procedures. Other NRC.

,

inspections provided additional input to the assessment of plant operations.

Management involvement was apparent in the preplanning and assignment of activities for tas.k completion. This involvement was evident in the development and implementation of a Readiness for Operations program,~ implementation of the Trip. Reduction program, inclusion of the Initial Startup program under thein direct control of the operations department, and training,lected the requirements of 10 CFR 50.72 and 10 CFR 50.73 using se events.

Management involvement was not a> parent in the initial identi-

-

fication and assessment of AFW cieck valve failures prior to HFT. As a result a significant check valve backleakage event occurred. Management involvement was also poor in the initial follow-up, assessment, and corrective actior, for this event. As a result, a second event that was more severe occurred 12. days later.

The NRC team inspection of operations procedures determined that administrative control procedures were not thoroughly understood as evidenced by inconsistencies and contradictions.

It appears that the administrative review cycle was not effective in ioentifying and correcting the large number of deficiencies within the plant operating procedures. Examples of field procedures that were in conflict with the controlling pro-grammatic procedure were found. Once this issue was identified

-

,

t

llbc..

_._.

_.

. __

_

_. _ _ _ _ _ _ _

_

_

s..

.~

g

,

.'

,

,

'

- 15 -

'

,

h to plant management, the applicant initiated corrective action

'

to address these concerns.

!

Operational decisions were generally conservative and made with the emphasis placed on plant safety.

Some failures to document

,

L operational events or identified preoperational problems were noted. However, when these-issues were escalated.to senior l

management attention, the issues were resolved. The applicant.

'

),

was almost always responsive to NRC concerns and questions.

In.

those instances where the response was slow, management took

o immediate corrective action to resolve the issues.

!L Three violations were issued in the area of preoperational test performance: one for failure to properly document a' deficiency;

'

. and two for failure to follow procedures. These two had several examples and appeared to be the result of poor quality preopera-

-

tional test procedures and hurrying on the part of operators.

An apparent violation associated with the AFW system backflow event was identified. An apparent violation is a repetition of

?.

the: failure to follow procedure violation discussed below and is

,

- a pending enforcement issue.

A few instances of a failure to follow procedures by operators

.

l and test engineers were noted during the preoperational test

-.;

program.

In one instance, the failure to follow the procedure resulted in' initiating hot water backflow from the steam--

generators into AFW piping because several check valves failed to seat. The applicant's performance relative to this opera-j tional event was not satisf actory. The leaking: check valves had

,

been identified prior to heat-up for hot functional' testing.

)

~

1-Operators and management failed to.' recognize the significance of

.

the= leaking check valves. Both vertical communication between

]

operators'and their management and-horizontal communication between shifts was not adequate to preclude event recurrence.

-)

As a result, another failure to follow procedure resulted in an g

'

. additional more severe backflow from the steam generatorsLinto the AFW-piping. This additional event was not included in.the applicant's deficiency reporting system until more than_ a ' week after the event occurred. The problems in this: area apparently stem from the operations department not attaining a sensitivity to events which affected the operability of important systems.

After the AFW backflow events, the applicant demonstrated an increased sensitivity to events, such as the loss of RHR during mid-loop operations.

.

The applicant's prestart test group satisfactorily perfurmed numerous system and component level tests. These included major milestone tests, such ag Coritainment Integrated Leak Rate Test, Loss of Offsite Power Tdst,' Integrated Hot Functional Test,

.

,

i

.

l

..

-e T'

-.

.

.

.

. -

m

-

.

'

-

'cih

.

.

.

.

,

,

and' Engineered safety Features Actuation Test. Management was generally involved in preplanning and assignment of-priorities in test scheduling. Test persont.el performed their duties in a professional manner.

The number of available operators and shift supervisors exceeded the minimum number required for single-unit operation and was

,

adequate for two-unit operation. The additional shift personnel-were being used to assist in Unit 1 preoperational testing.

Although the licensed operators, as a general rule, do not have much power plant operating experience, senior management recognized this weakness and took steps to remedy this condition by obtaining-hot operating experience for the Comanche Peak operators at similar facilities.

NRC inspection of-the applicant's training program for operations and operation support determined that, in general, training of personnel has been appropriate. A few instances of personnel failure to follow procedures have resulted in retraining.

Operations-personnel maintained a. professional demeanor in the control room. Lines of authority were clearly established and

<

maintained by the on-shift personnel. Name tags clearly identi-fied each operator by-name and position. Preshift briefings and-turnovers are performed in a professional manner and contain the-necessary detail to assure that an adequate transfer of knowledge is accomplished within the control room.

,

2.

Performance" Rating-

- The applicant's rating is Performance Category 2 in this area.

3.

Board Recommendations a.-

Recommended.NRC Action

,

None.

b.

Recommended Applicant Action Management should ensure effective implementation of the operational readiness program and related corrective action efforts, such as procedure corrections.

E.

Maintenance-and Surveillance 1.

Analysis

This functional area includes all activities associated with either diagnostic, predictive, prev'entive or corrective

.

+

-

-

_

.

-

n..

..

-.

--

.

-

--

..

3 w..

'

,-

.

,

'

- 17 -

.

maintenance of plant' structures, systems, and components;-

-procurement, control, and storage of-components, including qualification controls; installation of plant modifications; and maintenance of the plant physical condition.

It includes conduct of all surveillance (diagnostic) testing activities as -

.

well as all in-service inspection and testing activities.

Examples of activities included are instrument calibrations;-

'

equipment operability tests; post-maintenance, post-modification, and post-outage testing; special tests; in-service inspection'-

'

and performance tests of pumps and-valves; and all other in-service' inspection activities. Also included in this assessment are activities associated with lay-up of systenis which are not in use.

The-input for the assessment of the applicant's performance.in this functional area.was derived from various NRC inspections including the team inspection of operations and maintenance procedures.

In-depth review of the. maintenance QA program determined that the program was adequate..Although maintenance procedures were in use and appeared to be technically adequate, numerous discrepancies in the procedures, their format, anc their control'

-

were noted.

In addition, weak control of in-process Instru-mentation and Control work records resulted in a violation for

which the applicant was implementing corrective and preventive actions at the end of the SALP, period.

In another case NRC's

.

ins,nact4n of procedures for post-work testing.found that the

.

applicant had identified a number of-missing post-work test

'

completion reports. The applicant was implementing-corrective actions at the end-of the SALP period.- Another violation in

"

this area concerning the substitution'of carbon steel bolts for silicon bronze bolts-occurred in 1987 and appeared not to reflect the current maintenance program.

The applicant surveillance test program was complete and was in the process of_being implemented. The program adequately addressed the procedures, methods, and rules for scheduling,

tracking, statusing, performing, reviewing, and managing the, surveillance tests.

Staffing levels for maintenance and surveillance activities appeared to be adequate. Although a backlog of maintenance work orders existed, the applicant has taken effective action to reduce the overall number.

Management has taken an active role in the area of maintenance training. The applicant's maintenance training facility is i

particularly noteworthy.

NRC observation of maintenance activities revealed that maintenance personnel were knowledge-able of procedural requirements and were working to current l'

.

.

'

'

... -. - -.

-

.. -

-

-..

.

.

.

3.

.

,:

'. -

'

[

t

'

--18 -

l

'

procedures. Personnel performing required surveillances were also found to be knowledgeable of requirements and working to current procedures. The satisfactory performance of maintenance and surveillsnce personnel was indicative of a satisfactory

- 1

'

training program.

2.

performance. Rating

.

The applicant's rating is Performance Category 2 in this area.

3.

Board Recommendations (a) Recommended NRC. Actions None.

-(b) Recommended Applicant. Action None.

L F.

Security

'

1.

Analysis

,

L This functional area includes all activities that ensure the security of the plant including all aspects of access control,

.

security background checks, safeguards information protection, and fitness-for-duty activities and controls.

,

,

L Five preoperational inspections were conducted by physical-

'

l security inspectors during this assessment period. Several l

minor problems were identified. The applicant has: corrected-most of the identified problems and is working on resolution of the remainder.

The applicant's security organization has implemented an

"

aggressive program for the self-identification of security-

problems to ensure compliance with the requirements of 10 CFR Part 73 and the Physical Security Plan (PSP). Corrective actions initiated as a result of the applicant or NRC identifico problems have been technically correct and effective. Plant ana corporate management. has been supportive and actively involved in providing timely solutions to issues identified by the E

security staff. The applicant has been responsive to NRC initiatives.

The applicant' appears to have a sufficient number of security supervisors, fully qualified security officers, and security support personnel assigned to the security depa'rtment to

-

implement a proper security program during normal operations during the transition from construction to operation. However,

a b

-

.

-

- - - - - - - - - -

. - -

- - -

-

,

.

-

--.

.

-

.

.

-

-

.

'.l,. 3.;

..

..

.,

,

- 19 -

'

'

.

during the transition from construction to operations overtime use appeared to be excessive and, thus, could have a negative-impact on security staff effectiveness. Applicant management has~ recognized this problem and has initiated actions to hire j

L more security personnel. The lines of authority within.the security force are clear and well-understood. Only one minor.

deficiency.was identified with the security training program.

.

A more accurate assessment of the-training program will be possible following the completion of lockdown, but it appears

'

that~ security force personnel have a good understanding of thel.

applicant's policies and procedures. The applicant has established the necessary procedures to provide for the implementation of a proper security program.

,

The transition to a security organization responsible for safeguarding an operating nuclear power plant from a long-term tsecurity organization responsible for industrial protection has

.

not been implemented to a degree that has permitted the inspectors L

to establish the assurance of acceptable performance in this

~-

area. The applicant initiated a three-stage phased lockdown of the protected and-vital-areas on July 1,.1989. Phase ILwas completed and. portions of Phase 2 were accomplished prior to the end of this assessment period.

It appears that applicant management did not recognize that the plant was not ready to-enter into the-final phase (hard lockdown), but has since.

acknowledged that fact. The applicant has committed to

~ erforming an internal' security program self-evaluation, to p

cormet any deficiencies identified and to inform the NRC when they consider the plant ready for completion of the pre-operational' inspection.

Based on the~preoperational inspections completed.to date, it appears-the applicant has-established the

-

basis for an acceptable security program.'

'

t The applicant's submittals with respect to safeguards matters

'

were technically sound and consistent. These submittals' indicate that the applicant has well-developed policies and procedures for control of security related activities. During this-assess-ment period, there was consistent evidence of prior planning and involvement by utility management.

2.

Performance Rating The applicant's rating is Performance. Category 2 in this area.

,

,

.

The change in rating from a Category 1 (last SALP period) to a Category 2 does not necessarily reflect a change in applicant's performance. The last SALP rating was based primarily on the acquisition, installation, and activation of state-of-the-art i

security equipment which demonstrated the applicant's commitments to the security program. The applicant had not yet implemented

.

-.

.

.

.

.

- _.

.

.

. -. - - - -.

- _ _ -..

.

jN.

,:,.

,

- 20 -

q

the security plan. The final rating for the security program

,

,

D-was impacted by the fact that the applicant elected to " lock-

,

I down" while there was a' substantial amount of construction still ongoing. The present SALP rating is based on additional activi-ties necessary to demonstrate implementation of the physical security plan which was scheduled to occur after the SALP period

,

'

ended.-

3.

Board. Recommendations W

!

a.

Recommended NRC. Action None.

'

b.

Recommended. Applicant. Action, None.

G.

Radiological. Controls L

1.-

Analysis l

The assessment of this functional area consists of activities L

directly related to radiological controls, including occupational radiation safety (e.g., occupational radiation protection, y

radioactive materials and contamination controls, radiation field control, radiological surveys and monitoring, and as-low-as-reasonably-achievable (ALARAl programs), r,adioactive waste

.

management (i.e..; processing and onsite storage of gaseous, P

liquid,andsolidwaste),radiologicaleffluentcontroland

,

>

monitoring:(including _gaseousandliquideffluents,offsitedose calculations, radiological environmental monitoring, and con-firmatory measurements), water chemistry controls and transpor-tationof-radioactivematerials(e.g.,procurementof-packages, preparation for shipment, selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of-packagings, and point-of-origin safeguards activities).

The occu)ational' radiation safety program was -inspecteo twice during t1e assessment period by radiation specialist inspectors.

Several open items were identified involving spent fuel transfer tube radiation levels, installation of health physics instru-mentation, ALARA personnel involvement with planned work activities, hot particle identification and' control, skin.

exposure from Xenon, and startup shield surveys. The applicant's responsiveness to NRC initiatives and the resolution of tecinical issues has been good.

.

The applicant has maintaine'd a stable, experienced radiation l

protection staff. The personnel turnover rate within the

.

O

.

l g c'j a

.-

.-

.,

,

'

'

'#

21 -

.

occupational radiation protection staff during the assessment--

period was below 15 percent and vacancies were routinely filled in a-timely manner. Management involvement and control is evident by thel prior planning and assignment of priorities.

In order to maintain.a proper level of applied experience, the-applicant has routinely sent radiation safety personnel to work at operating power reactors during both outage and nonoutage activities.

.

The applicant's radiochemistry and water chemistry programs were.

inspected once during the assessment period. Five open items were identified involving corporate technical support for the.

onsite chemistry group, primary chemistry and secondary sampling system testing, completion of-chemistry laboratory facilities, and completion of the testing'and operations of the post-accident sampling system.

^

The applicant's transportation = program for radioactive waste management was inspected once during the assessment period. The applicant-had the necessary organization, training, and procedures in place to implement a proper radioactive transportation

_ program.

The radioactive waste management program was inspected once during the assessment period. Seven open items were identified concerning the radwaste program.. These' items involved the

-

organization and staffing of the operations radwaste group; liquid radwaste system preoperational tests;-gaseous radwaste preoperational tests and calibration of effluent monitors; solla radwaste spent resin transfer system modification, testing; sampling, and process control program; air cleaning system-preoperational tests and system balancing; radiation monitoring instrument calibration and functional tests; and a comprehensive

~

audit of the radwaste program.

The radiological environmental monitoring program was not inspected during this assessment period. This area has been.

'

reviewed annually since the early 1980s and all open items and commitments have been completed. The Offsite Dose Calculation Manual, Revision 0, dated March 1989, had been approved by the Office of Nuclear Reactor Regulation (NRR).

Other reviews conducted by NRR staff included several open items, an issue concerning the qualification'of the manager of Raciation Protection, and FSAR amendments. These issues were resolved by requests for additional information, teleconferences, meetings, and a plant walkdown.

The-applicant's internal audit program for radiological control activities has been in effect for several years. The applicant supplements quality assurance personnel with corporate or vendor e

_

. _.

_

__ _.

_

__4

_

jy y

,

,

'

- 22^-

i

technical-specialists._ All audits have included a team member with technical experience in the area being audited.-

Station procedures have been developed and are in place for most-radiological control activities associated with plant operations.

Those procedures not yet implemented are in the development stage and.are scheduled for completion prior to criticality.

'

The applicant has established good lines of communication between the training department.other station groups, and the radiological control group.

No major problems were identified in the radiological controls

,

area regarding the effectiveness of the. training and qualifi-cation program.. The applicant's staff appears adequate to implement the radiological controls program. The applicant's overall readiness and capability to support plant operations is

,.

considered to be adequate.

2.

Performance. Rating The' applicant's rating is Performance Category 2 in this area.

'

This SALP rating is based on the evaluation of the applicant's

.

preparation for implementing the radiological protection program which was scheduled to occur after the assessment period.

3.

Board. Recommendations

.1 a.

Reconnended.NRC Action

.

None.

-

b.

Recommended. Applicant. Action None.

'

'

H.

Emergency Preparedness 1.

Analysis This functional area includes activities related to the establish-ment and implementation of the emergency plan and implementing procedures; such as, onsite and offsite plan development and

.I coordination; support and training of onsite and offsite emergency response organizations; applicant performance during exercises and actual events that test emergency plans; _ admini-stration and implementation of the plan (both during drills and actual, events); notification; radiological exposure control; recovery; protective actions; and interactions with onsite and j

.

offsite emergency response organizations during exercises and actual events.

e

-

L

-

.,

.

.

,

.

.

-

- -. -

.

.

-

-

-. -.

-_

.

.

-

ym.;

.

..

.y

- 23 -

"

Two, team inspections were performed during the assessment period involving emergency preparedness. One was an emergency pre-paredness implementation appraisal and the-other was an evaluation of the applicant's performance during an emergency exercise.

A review of the applicant's emergency preparedness staff showed-that their qualifications and experience were adequate..The

_ applicant's description of the emerg'ency response _ organization

'

identified organizational response elements but needs further clarification of its structure regarding the assigned responsi -

bilities. The applicant has the necessary staff in place to

.

support emergency preparedness activities.

An emergency preparedness training program has been established, however, qualification requirements for each position were not

.

clearly specified and practical training was not required. A large portion of the training for the emergency responders had been-provided,.but the changes'to the emergency organizational structure'and the ongoing work on some plant systems will require further training.

In addition, a small number of emergency responders has not received training consistent.with their duties at the time of the-appraisal. Those portions of-

-

the emergency response facilities that had been completed were satisfactory; however, some emergency facilities (e.g.,

technical s!.,pport center) were still in various stages of

,

t l;

completion, and:some equipment and supplies were not in place.

Demonstration of personnel accountability and evacuation of the protected area and evacuation of the owner-controlled area'were not accomplished during the emergency preparedness nercise.

-The applicant has a unique situation.in this regard due to a i

large number of workers in the protected and owner-controlled t

areas; Specific deficiencies were:found in some proceoures, _

_":

mainly in the procedure used for making protective action recommendations. These deficiencies included the absence of

-

operational assessment of plant conditions, and the inclusion of extraneous considerations which may impact on the timely release

,

L-of protective action recommendations.

1:

L The relatively_small number of findings that resulted from the I

appraisal indicate that the applicant _has made a~ strong commit-

~

.1 l.

ment to the emergency preparedness program. The significant l

findings identified in the appraisal need to be corrected in I

order for the applicant to implement an adequate emergency preparedness program.

An emergency exercise inspection was also conducted during this assessment period. Although seven open items were identified

'

'

during the exercise, the inspection team concluded that the applicant had demonstrated the cbility to implement the emergency L

{

-.

-

.

_.

__

_._._

.

__

E.

-

.

...

,

,

--24 -

,

,

plan in order-to protect the health and safety of the public.

In addition, the inspection team' concluded that the applicant's internal assessment program was able to identify and properly

'i characterize its own deficiencies.

The applicant has demonstrated a strong comitment to provide management support to the development of a quality emergency preparedness program. This commitment involves training program.

improvements, installation of state-of-the-art facilities and.

equipment, and moving the operational support center to a better.

location.

In addition, the applicant has implemented an aggressive and-comprehensive audit program to identify potential problem areas.

.

Applicant audits conducted ~since August 1988 have resulted in a relatively small number of significant findings.

,

The applicant's ongoing interaction with offsite agencies appears to be adequate. The applicant has developed the necessary _ emergency implementing procedures to ensure that emergency activities are properly addressed.

2.

Performance Rating The applicant's rating is Performance Category 2 in this area.

lf 3.

Board. Recommendations a.

Recommended NRC. Action None.

-

-

b..

Recommended Applicant Action-

Correct the "significant" findings identified in the appraisal.

V.

Supporting. Data. and Sumaries A.

Applicant /NRC. Activities During this assessment period, September 1, 1988, through August 31, 1989, the applicant has been engaged in those activities ne.cessary

,

to complete the Corrective Action Program (CAP) and those activities necessary to demonstrate the operational readiness of Unit 1. -The activities required to complete the CAP are described in TV Electric

,

Project Status Reports (PSRs) which address 11 specific areas of

'

design and construction. The PSRs present the.results of the Design.

i Validation Program and describe the actions of the Post-Construction Hardware Validation Program (PCHVP). The PSRs also provide for a final reconciliation of the validated design and the validated h

'

.

.Ea

-.

.

f

.

..

.

..

.

.

.

.

.

~

f,p o

.

+

<

l

' '

- 25'-

l hardware to assure that the as-built' plant is consistent with the.

,

P

. validated design.

u L

The activities performed to demonstrate the operational readiness of Unit 1consistedprimarily)of(1)thecompletionofprerequisiteandthe performan i

preoperationaltesting,-(2 L

such as the graded Emergency Preparedness Exercise, and (3) the preparation of Site Radiation Protection and Site Security programs..

.

u Majortestsperformedduring)theSALPperiodincludedperformanceof L

the Hot functional Test (HFT, the ASME VT-2 Pressure Test of the Q

ReactorCoolantSystem(RCS)whichwasconductedasasupplementto tie previous Cold Hydrostatic test of the RCS, the Containment IntegratedLeakRateTest(CILRT),andtheIntegratedTestSequence (ITS).

L At the end of the assessment period, Unit I construction was L

essentially complete.

Construction activities on Unit 2 have been l

limited by the applicant to those activities required to support Unit 1 operation and to minimize Unit 2 construction personnel in Unit I areas after Unit I goes into operation.- Construction of L

. Unit 2 is approximately 85% complete. This-assessment is applicable-l to applicant's cctivities on both Unit I and Unit 2.

B.

NRC Direct. Inspection and. Review. Activities i-NRC inspection activities during this SALP-evaluation period are documented in 91 inspection reports with over 21,000 direct inspection

-

hours expended. The maiority of the NRC inspect 1ons covered the applicant's activities for the construction program,' the CAP, and the

.

l preoperational test program. The_NRC inspections included specific activities of the applicant to demonstrate operational reaoiness.

NRC inspections performed included three team inspections of the CAP, and team inspections of equipment qualifica' tion, pump and valve operability, seismic qualification, graded emergency exercise, emergency preparedness, emergency operating procedures, operations-and maintenance procedures, and licensed operator requalification examinations. The NRC also conducted specific inspections of the L

Radiological Controls Program, the Security Program, chemistry and

,

radiochemistry, and the Preservice Inspections (PSI) program.

In November 1988 the NRC staff issued evaluations of the. applicant's CAP relative to the technical disciplines of mechanical; civil /

structural; electrical; instrumentation and control (I&C); and HVAC.

Additionally, Supplemental Safety Evaluation Report (SSER) 20 (to NUREG-0797), also issued in November, addressed the staff's evaluation of the implementation of the CPRT Program Plan and the f

Issue-Specific Action Plans, as well as CPRT assessments of certain CPSES programs and hardware.

l

!

-

.

-

.

.

-

~ _

..

.

.

--

. - - -

.-

-

-

- -

jfog :

..<,

,

l:.'

'

- 26 -

.

+

L L

In May of.1989 an NRC AIT reviewed-the applicant's investigation and L

corrective actions related to AFW check valves which failed during L

the HFT.

In April 1989, the NRC staff issued SSER 21 which reports the status of certain licensing issues that had not been resolved when earlier supplements of the Safety Evaluation Report were published. This supplement also lists new issues identified since SSER 12 was issued and includes evaluations of-licensing items resolved in the interim period.

C.

Enforcement Activit.y No civil penalties were proposed or issued during the assessment period. On November 9,1988, an enforcement conference was held to discuss NRC findings regarding coating removal from the service water-

,

piping system and the applicant's performance for:

(1) procuring i

1.

contractor services for the removal, (2) controlling the special process used for the removal, (3) inspecting and monitoring the process, and (4) taking prompt and effective corrective actions for u

identified deficiencies. Although escalated enforcement action was

.1

,

considered, four Severity Level IV violations were issued. These

'

issues.are still open and the results of a follow-up inspection are under review in NRC Headquarters.

'I On February 28, 1989, a Severity Level III violation was issued for J

-

the failure in 1986, to submit a timely. request for extension of the J

Unit 1 construction permit.

No civil penalty was issued because of

'

the corrective action that was taken, the age of-the violation, anc the lesser safety-significance of the violation.

'

b

< As a result of the Augmented Inspection Team (AIT) report issued July.

10, 1989 (50-445/89-30; 50-446/89-30), the NRC identified three.

apparent violations of NRC regulatory requirements. The substance of-i p

the three apparent violations has been communicated to the applicant j

during an NRC monthly exit meeting held September 5,1989, but -no i

'

violations have yet been issued pending an enforcement conference.

Although not formally issued during the assessment period,-the three apparent violations accurred in this assessment period.

l Table I provides a tabulation of NRC enforcement activity for each functional area during the assessment period.

• D.

Confirmation.cf Action. Letters On May 5,1989, a confirmation of action letter was issued regarding backleakage through the failed check valves in the AFW system that

,

l-had occurred during the Unit 1 HFT. The letter confirmed the actions L

that the NRC understood TU Electric to be taking in preparation for the NRC AIT.

In brief, the letter required the following:

the l'

l-

,

-

.

.

.

.

.-

-..-

..

.

- _

.- __

-.

6o

,.

,

,,.. -

%

<

- 27 -

!

y gathering of all pertinent documents, performance of required testing and corrective actions, consideration of generic implications, and

>

involvement of the NRC AIT in ongoing activities. Activities of the Augmented Inspection Team that evaluated the applicant's follow-up actions are documented in NRC Inspection Report 50-445/89-30; 50-446/89-30.

'

E.

Alleastions

'The applicant has continued to demonstrate sensitivity towards j

allegers and employee concerns. As part of the Joint Stipulation to j-dismiss the ASLB proceedings Ms. Billie Garde, attorney for Citizens Associatiun for Sound Energy, addressed all applicant and contractor supervisors and managers regarding employee concerns. Over a two-month period, Ms.. Garde gave a two-hour presentation to 25 classroom-size groups of supervisors and managers to increase their under-standing and awareness of the importance of the proper handling of employee concerns.

The applicant has methods in place by which employee concerns are-received and resolved.in a controlled manner. Employees are encouraged to take their concerns to supervision, to the management i

hot line, to SAFETEAM, or to the NRC.

J At the beginning of the assessment period there were 29 open allegations. During the assessment period 26 allegations were g

l received and 44 allegations were closed. At the conclusion of the assessment period. 11 alleaations remained open. The low number of allegations received by the NRC indicates'that the applicant's-programs for addressing employee concerns are effective.

1 1. i

.

p

.-

.

l

-

L L

l

.

-

L l

.

.

-

.

.

.

.

-

.

.

.

.

n'

~

. e n =,- o

)

..

... -..

,

r

~O

- 28 -

l i

TABLE 1*

ENFORCEMENT ACTIVITY

.,

..

.

....... -.....

.......

.

....

..

.

..

FUNCTIONAL. AREA....

....Dev...V...IV...III..II.

.I.

....

.....

J Construction & Corrective Action Programs

2

0

0-Engineering / Technical support

1

0

0 Safety Assessment / Quality 0-

3

0

Plant Operation

1

0

0-Maintenance / Surveillance

0

0

0

-

Security

0

0

0 Radiological Controls

0

0

0 Emergency. Preparedness

0

0

0 Other**-

0

1

0

~i

..

.

....

......

....

....................

Totals

4

1 0-

"

'

• This table of enforcement activity does not include three apparent

'

violations resulting from the AIT findings and included in the exit-meeting conducted on September 5, 1989. These apparent violations have not yet been-issued.

.

• • This violation occurred in 1986 and was due to the failure of TU: Electric to submit a timely request to maintain the construction. permit for Unit 1.

Although the violation was issued in this SALP period, it does'not reflect the performance of the applicant during this SALP-period.

.

9.

,

-