IR 05000445/1989010
| ML20236D322 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/14/1989 |
| From: | Hale C, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236D302 | List: |
| References | |
| 50-445-89-10, 50-446-89-10, NUDOCS 8903230056 | |
| Download: ML20236D322 (10) | |
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U. S. NUCLEAR REGULATORY-COMMISSION,
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I OFFICE OF NUCLEAR REACTOR REGULATION
'50'445/89-10 Permits: CPPR-126~
- NRC Inspection Report:
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50-446/89-10 CPPR-127
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l Dockets: 50-445 Category: A2-50-446 I
Construction Permit Expiration Dates:-
Unit 1:" August 1, 1991 Unit 2: August 1, 1992 lo 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:
February 8 throdgh March 7, 1989 Inspector:
CU 9k-C.
J.' Hale, Reactor Inspector Date Consultant:
J. Birmingham, Parameter (paragraphs 4 and 5)..
Y Rev'iewed by:
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H. H.: Livgpmore,-LeapUSenior Inspector
' Date 8903230056 890314
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Inspection Summary:
Inspection Conducted:
February 8 through March 7, 1989 (Report 50-445/89-10; 50-446/89-10)
Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, design changes and modifications, engineering functional evaluation, QA program administration, and applicant meetings.
Results:
Within the areas inspected, no violations or deviations were identified; no significant strengths or. weaknesses were noted.
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i DETAILS I
1.
Persons Contacted
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- R.
W.
Ackley, Jr.,. Director, CECO
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- M.
Alexander, Manager of Materials Management, TU Electric i
- J.-L.
Barker, Manager, Engineering Assurance,.TU-Electr.ic.
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- D.
P. Barry, Sr., Manager,-Engineering, SWEC-
1*J. W.
Beck, Vice President, Nuclear Engineering, TU Electric l
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- H.
D.
Bruner, Senior Vice President, TU Electric
- J.
Buck, Senior Review Team-
- W.
J.
Cahill, Executive Vice President, Nuclear, TU Electric l
- J.
T.
Conly, APE-Licensing, SWEC:
- W.
G.
Counsil, Vice Chairman, Nuclear, TU Electric
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- C.
G.
Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric-
- G.
G.. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric
- D.
E. Devincy, Deputy Director, Quality' Assurance (QA),
j TU Electric l
- J.
C.
Finneran, Jr., Acting Manager, Civil Engineering, l
l TU Electric j
- C.
A.
Fonseca, Deputy Director, CECO
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- W.
G.
Guldemond, Manager of Site Licensing, TU Electric
- T.
L. Heatherly, Licensing Compliance Engineer, TU Electric
- J.
C.
Hicks, Licensing Compliance Manager, TU Electric l
- C.
B.
Hogg, Engineering Manager, TU Electric
- S.
D. Karpyak, Nuclear Engineering, TU Electric
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- J.
J.
Kelley, Manager, Plant Operations, TU Electric
- J.
J.
LaMarca, Electrical Engineering Manager, TU Electric
- 0.
W.
Lowe, Director of Engineering, TU Electric
- J.
W.
Muffett, Manager of Engineering, TU-Electric
- W.
E.'Nyer, Consultant, TU Electric
- E.
F.
Ottney, Program Manager, CASE
- S..S.
Palmer, Project Manager, TU Electric
- W.-J. Parker, Project Engineering Manager, SWEC/ CECO
- A.
Pereira, Assistant to Deputy Director, QA, Ebasco
- D.
M. Reynerson, Director of Construction, 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
- C.
L. Terry, Unit l' Project Manager, TU Electric
- D.
R. Woodlan, Docket Licensing Manager, TU Electric
- J.
E. Wren, Assistant Director to QA for Administration, TU Electric The NRC~ inspectors also interviewed other applicant employees during this inspection period.
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- Denotes personnel present at the March 7, 1989, exit meeting.
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2.
Applicant Action on Previous Inspection Findings (92701)
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(Closed) Open Item (445/8810-0-06; 446/8808-0-06):
The
process was not clear whereby the applicant assured that all (
required records were being captured in the records management
. system.
Procedures have been. established to assure that all required-records are obtained from the groups originating the records.
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The major record generating. groups are engineering,
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procurement, construction, and QA.
The controlling procedures in each area'are:
(1) ECE 9.15, " Development of Design Production Transition Reports," for engineering' contractors; l
(2) ECE 5.19, " Review of Vendor Documents," for. procurement;
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(3) NQA 2.13, " Quality Assurance Records Program," for-QA; (4) ECE 2.13, " Control of Documents Designated to Become Records," for Comanche Peak Engineering; and (5) ECC 2.13-3, 2.13-4, 2.13-6, and 2.13-7 are procedures which provide the direction for the generation, use, control, and turnover of construction work packages by the construction group.
The NRC inspector reviewed each of these procedures'and discussed their use and implementation withithe responsible
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personnel.
In each case the required documents were verified as being retained and these documents were continuously
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tracked and accounted for until turnover to records management.
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personnel.
Verification-by the NRC inspector that these
processes have been established closes this open item.
3.
Design Change and Modifications (35744)
Two programs are in effect onsite for processing design i
changes.
Each program has the same basic programmatic requirements; i.e.,
established and controlled procedures,.
i verification of design inputs; required reviews and approvals,
.j including independent design verification; and control of revisions'to design changes.
For purposes,of discussion in this report, the change documents used in these two programs are the design' change authorization (DCA), used in those-plant
.i areas still under construction and the design modification (DM), used in those areas under the control of plant'
operations.
The DM will be the principal change document used after issuance of the operating license.
The NRC inspector reviewed the procedures developed for control of all design changes.
The procedures used by construction and' engineering for the control of DCAs included:
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- NEO 9.17, " Initiation, Review, and Approval of Design Modification Requests - Construction Phase"
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i-ECE 2.ll-II, " Design Change Trending"'
ECE.5.01-03, " Design Change Authorizations" ECE 5.09-01, " Design Verification an'd Interdiscipline Review" The procedures used by operations.and engineering to control
'DMs and temporary modifications-(those!non-permanent facility changes usually11asting less than 90. days) included:
NEO 3.03, " Preparation, Review, and Disposition of Plant Design Modifications" i
NEO 3.17, " Initiation, Review, and Approval of Plant' Design;
-i Modifications"
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NEO 8.01, " Temporary Modifications" These procedures provide the required control of facility design changes, during both construction'and subsequent' plant i
operation, such as:
documented evidence of reviews, evaluations,'and approvals; identification, review and approval of design-inputs; identification-of organizational
design interfaces (internal and external); independent design verifications; final approval of~ design' changes to assure all requirements have been met; and distribution of approved design changes as well as? recall of' superceded documents.
The
.same process'is used when. design change' documents are: revised.
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-The personnel performing the work associated with design changes are either from the organization' responsible for the initial design or. equivalently, qualified.
In-additionoto the above requirements, the operations procedures (principally
'NEO'3.03) required:
'each change / modification be evaluated-for unreviewed safety < questions.and if the technical.
specifications were affected that proper fire protection and prevention requirements were appropriately considered; plant procedures affected by.the: change were revised and.the
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necessary operator training'was, conducted; and that any post I
modification acceptance testing was performed using approved
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test procedures containing testing requirements and criteria.
To verify these procedural requirements were being implemented the NRC inspector will select completed design change document-packages for inspection during the next inspection period.
tka violations or deviations have been identified.
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4.
Engineering Functional Evaluation (35060)
'l In the latter half of 1986, TU Electric made a decision to develop and implement a Corrective Action Program (CAP) to
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address concerns for the adequacy of design and construction at CPSES.
Two separate programs, the Technical Audit Program (TAP) and the Engineering Functional Evaluation (EFE), were established to assess the adequacy of the CAP design and hardware validation process.
Further the EFE was expanded to include supplemental efforts to assess CPSES readiness for operation in the areas of design data utilization and design control.
The original scope of the EFE, the design and
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hardware validation process of the CAP, was designated Module 1, the supplemental areas were designated Modules 2, 3,
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and 4.
NRC inspection of the overall adequacy and effectiveness of the TAP has been ongoing since TAP inception.
The results of the most recent NRC inspection of the TAP are documented in NRC Inspection Reports 50-445/88-55, 50-446/88-51 and i
50-445/88-75, 50-446/88-71.
These inspections were, for the most part, satisfactory.
NRC inspection of the adequacy of the TU Electric Design Validation Program (DVP) included documents in the scope.of
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Module 1 of the EFE.
Such documents were included in the NRC inspections in order to assess the effectiveness of the EFE in identifying problems.
The results of the NRC inspection of j
the CPSES DVP were issued in NRC Inspection Reports I
50-445/87-19, 50-446/87-15 and 50-445/87-37, 50-446/87-28.
These inspections included several items that are being followed for. closure and as yet, are not complete.
Apart from i
this followup activity, no further NRC inspection of Module 1
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activities is planned.
Modules 2, 3, and 4 of the EFE are designed to assess how well design data, validated in Module 1, are utilized in startup,-
maintenance, and operations activities.
Assessment of the adequacy of design data utilization for startup and
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maintenance (Modules 2 and 3) is being accomplished by the TU Electric audit program.
Module 4, assessment of design control by operations, is intended to be accomplished by TU Electric Engineering Assurance and TU Electric audit program.
This module is scheduled to be performed during the startup and initial operation phases of CPSES.
NRC inspection
of these activities will be reported as the module is performed.
During this inspection period, the NRC inspector inspected:
(1) the procedure for completion of EFE reviews, (2) the qualifications of personnel designated to perform those reviews, and (3) the results of two EFE audits of design data
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utilization by startup (Module 2).
The inspection results
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follow.
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l NEO Procedure 9.16, " Engineering Functional Evaluation
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Transition and Completion Program" was issued to establish the responsibilities and to define the process for the completion of EFE Modules 2, 3, and 4 and for the verification of proper closure of items resulting from NRC inspection of Module 1 activities.
The NRC inspector determined that the procedure adequately defined the personnel and the process for the
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completion of the EFE modules.
The procedure provided for the appointment of an EFE Completions Supervisor from the TU Electric audit group and a i
Lead EFE Completions Engineer from Engineering Assurance.
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Other personnel from the TU Electric Audit Department, Engineering Assurance, and SWEC Engineering were to be assigned as required.
The procedure was determined to properly require the completion of the EFE modules utilizing the review plans and review criteria documents developed by SWEC EFE.
Prior to use, the review plans and review criteria documents were to be updated to reflect current validated design data.
Qualifications of personnel performing EFE activities were
delineated for each module.
The modules required the use of engineering personnel experienced in the applicable aspects of nuclear power plant design for those portions of the program i
requiring design evaluations.
Those portions of the program j
requiring verification that validated design data were
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utilized by startup, maintenance, and operations were to be l
performed by personnel experienced with that phase of plant
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development.
Additionally, these activities were to be performed by or under the direction of a certified Lead Auditor.
Resumes of the EFE Completions Supervisor-QA and the l
Lead EFE Completions Engineer-EA as well as other audit j
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members assigned to the EFE program were reviewed and determined to meet the above criteria.
EFE audits 88-01 and 89-01 were reviewed by the NRC inspector for procedural compliance and content.
These audits were performed to evaluate the adequacy of design data utilization in CPSES testing programs (Module 2).
The audits were based on specific review sheets selected from the SWEC Module 2 Review Plan and were primarily for testing conducted on the Containment Spray (CS) system.
The review sheets covered the areas of prerequisite test program requirements, pressure and j
leakage testing of piping and components, flushing of piping and components, instrument calibrations, preoperational testing of the CS system, and the leakage reduction program.
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- The NRC inspector inspected the audit review sheets to determine:
(1) that appropriate and correct design criteria
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were specified for verification, (2) that sufficient i
documentation was reviewed to support review results, and (3) that conclusions as to adequacy of design data utilization were proper.
Further, the NRC inspector reviewed the audit reports to verify that deficient or open items were identified for followup in subsequent audits.
The NRC inspector's review of the audit review sheets and the documented audit results were satisfactory.
In summary, the NRC inspector determined that current EFE activities are adequately controlled by procedure and are being implemented by personnel with appropriate background and experience.
Audit activities for Module 2, appear to be sufficiently detailed and adequately implemented.
NRC j
inspection of subsequent EFE activities will be reported as j
these activities progress.
i No violations or deviations were identified during this j
inspection.
1 5.
QA Program Administration (35740)
During this report period the NRC inspector reviewed the
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administration of the applicant's QA program.
The following
areas were inspected to assure that:
(1) the scope and j
applicability of the QA program was adequately defined and had
been incorporated into lower tier procedures, (2) that the QA/QC program was adequately described in the QA manuals and incorporated into appropriately controlled QA/QC group procedures, and (3) that the applicant had established a mechanism for reviewing and evaluating the performance of the QA program and that methods exist for improving the QA program in " problem" areas.
This review evaluated the administration of the applicant's QA program and did not evaluate the implementation of the QA program.
Implementation of the QA program is inspected by the NRC during NRC inspections of the applicant's QA performance.
Documents reviewed during this inspection ranged from sections of the CPSES FSAR to minutes of the Senior Management Overview Committee meetings.
Results of this inspection follow.
The scope and applicability of the QA program is presented in the CPSES FSAR Chapter 17, Gections 17.1 and 17.2.
These sections address the QA program during plant design and construction and plant operations.
Additionally, Section 17A,
" List of Quality Assured Items" provides identification of structures, systems and components that are covered by the QA program.
Further, the NRC inspector determined that procedures such as:
(1) NEO 5.04, " Master Equipment List,"
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(2).ECE 5'04, " Master Equipment List,"fand (3) ECE 2.13-07,
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"CPSES Master Parts List (MPL)," require that specific
equipment and parts be identified as safety-related or:
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nonsafety-related.. These procedures also require the'.
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identification of seismic and/or environmental qualifications.
The NRC inspector reviewed engineering and construction Jprocedures to verify that consideration of.the safety-related
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status of a system, component, or item was required.
This requirement was determined to be appropriately included in
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i those' procedures.
For example, the procedures for procurement
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required a' review of an item's-status as safety-related, seismic, or environmentally qualified prior to issuing a-purchase order.
The NRC inspector. determined from the review of the FSAR and the above procedures that the scope and applicability of the QA' program was adequately defined in the FSAR and that QA program requirements were incorporated _into procedures.
The NRC inspector also determined that procedures
have been' established to develop controlled lists of QA program applicability at the equipment and parts level.
The NRC inspector reviewed the TU Electric and Brown.and Root (B&R) QA manuals.
These manuals prescribe the performance of activities affecting quality for all phases of CPSES, design and construction through operations.
Review.of these manuals showed that they require measures to be provided for each.of the 18 criteria of Appendix B to 10 CFR Part 50.
The TU Electric QA manual either contained or referenced specific procedures which controlled those activities required for compliance with requirements of Appendix B.
The B&R QA manual was found to require that measures to meet Appendix B requirements be prescribed in lower tier procedures.
The NRC
inspector reviewed lower tier procedures for both TU Electric
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and B&R organizations and determined that those procedures provided appropriate controls for preparation, review and approval of QA/QC group procedures, as well as the control of issuance, revision, and recall of QA/QC. group procedures.
This control of TU Electric QA procedures was provided by NEO Quality Assurance (NQA) Procedure NQA 1.03, " Development,
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Revision, Control and Distribution of TU Electric NEO Quality
Assurance Department Procedures."
Control for the B&R QA
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Procedure was provided by B&R Administrative Procedures AAP-6.1, " Preparation of ASME Procedures" and AAP-7.1,
" Control of ASME Procedures."
The NRC inspector determined
that these and associated procedures provided appropriate controls of QA/QC department procedures for QA/QC review, inspection, and audit activities.
The written program for periodic review of the QA program is contained in NEO policy statements and procedures.
Specifically, NEO Policy Statements 2 and-5 provide a requirement for a regular assessment of the QA program and i
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identifies the positions in management responsible for.
performing the assessment.
Further, Procedure NEO 2.20,
" Senior Management QA Overview Program," provides for regularly scheduled meetings of senior' management to address-identified problems in the QA program.
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The NRC inspector has reviewed the above procedure and-policy statements and determined that they adequately identify the methods.and responsibilities for periodic assessments of the QA program.
Further, the NRC inspector reviewed. minutes from the meetings of the Senior Management QA Overview Committee and regularly attends these meetings.
The meeting minutes showed that senior management is being, informed of the effectiveness of the'QA program and has been providing l
corrective actions for identified areas of weakness.
The NRC.
inspector verified that the annual assessment of.the QA
. program had been performed'for the 1987 time period and actions were ongoing for the assessment of the 1988 time period.
Through review of the content of the completed assessment and review of the-proposed plan for the current i
assessment the NRC inspector determined that appropriate inputs were being used for the assessments.
No violations or deviations were identified during-this inspection.
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Applicant Meetings (92700)
The NRC inspector attended applicant meetings concerning site activities and implementation of various site programs.
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Meetings attended during this reporting period included:
QA Overview Committee
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Recommendation Review Group
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While these meetings reflect management's involvement in day-to-day activities and attention to potential problems, no-violations or deviations were identified.
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Exit Meeting (30703)
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An exit meeting was conducted March 7, 1989, with the applicant's representatives identified in paragraph 1 of this
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report.
No written material was provided to'the applicant by the inspectors during this reporting period.
The applicant
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did not identify as proprietary any of the materials provided i
to or reviewed by the inspectors during this inspection.
During this meeting, the.NRC inspectors summarized the' scope and_ findings of the inspection.
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