IR 05000445/1989018

Insp Repts 50-445/89-18 & 50-446/89-18 on 890308-0404.No Violations or Deviations Noted.Major Areas Inspected: Follow Up on Violations/Deviations & Assessment of Allegations.Two Weaknesses Noted

ML20244C799
Person / Time
Site:	Comanche Peak
Issue date:	04/14/1989
From:	Hale C, Livermore H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20244C798	List: IR 05000445/1989018 ML20244C795
References
50-445-89-18, 50-446-89-18, NUDOCS 8904200420
Download: ML20244C799 (16)

Text

_ _ _ --

-- - - - - - - - - _ _ - - - - - - _ _ _ . - __ _ _ - . _ _ _ _ _ - - - - - . _ _ _ _ - _ _ _ . - - - -

b 7'.;

'

,

< .

, . -

.

, .

+

l H U. S. NUCLEAR. REGULATORY COMMISSION

. OFFICE OF NUCLEAR REACTOR' REGULATION"

!

.NRC Inspection Report: 50-445/89-18 Permits: 'CPPRi l26 .]

50-446/89-18

'

,

CPPR-127

, Dockets: 50-445 . Category: A2

'

50-446 Construction. Permit-Expiration Dates:

Unit 1:; August 1,,1991 Unit ~2: August 1, 1992 Applicant: TU Electric Skyway Tower 1

'400 North Olive Street Lock Bo:: 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: March 8 through' April 4, 1989 Inspector- hWL Y~/b66 pk C. J. Hale, Reactor Inspector Date-Consultants: J. Birmingham, RTS (paragraphs 2, 5, 6, and 7)

V- /Y-69

'

Reviewed by: -

~

f4 #uA V H. H. Livermore, Lead Senior Inspector Date 8904200420 890414 PDR O ADOCK 05000445 PDC

- _ _ _ _ _ _

-

i

f . --

, .

Inspection Summary:

Inspection Conducted: March 8 through April 4, 1989 (Report 50-445/89-18; 50-446/89-18)

Areas Inspected: Unannounced, resident safety inspection of follow-up on violations / deviations; assessment of allegations; design changes and modifications; procurement, receipt, storage, and handling; procurement program for nonconformance control and conditional release; and applicant meeting Results: Within the areas inspected, no violations, deviations, or unresolved items were identified. Two weaknesses were noted during this inspection: (1) the use and processing of. design change authorizations with confirmation required, identified as an open

. item (paragraph 4); and (2) schedular pressures may have caused a QC supervisor to use poor judgement and a QC inspector to do less than an acceptable job (paragraph 3).

l

_ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ -

r---

'

.

,

. .

DETAILS Persons Contacted

• R. W. Ackley, Jr., Director, CECO

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

• D. P. Barry, Senior Manager, Engineering, Stone & Webster Engineering Corporation (SWEC)

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

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

• H. D. Bruner, Senior Vice President, TU Electric

• W. J. Cahill, Executive Vice President, Nuclear, TU Electric

• J. T. Conly, APE-Licensing, SWEC

• C. G. Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric

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

• J. C. Finneran, Jr., Manager, Civil Engineering, TU Electric

• C.-A. Fonseca, Deputy Director, CECO-

• 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

• C. B. Hogg, Engineering Manager, TU Electric

• A. Husain, Director, Reactor Engineering,-TU Electric

• S. D. Karpyak, Nuclear Engineering, TU Electric

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

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

• D. M. McAfee, Manager, Quality Assurance (QA), TU Electric

• S. G. McBee, NRC Interface, TU Electric

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

• E. F. Ottney, Program Manager, CASE

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

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

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

• A. H. Saunders, EA Evaluations Manager, TU Electric

• A. B. Scott, Vice. President, Nuclear Operations, TU Electric

• C. E. Scott, Manager, Startup, TU Electric

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

• M. R. Steelman, Licensing, TU Electric

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

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

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

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

• R. D. Walker, Manager of Nuclear Licensing, TU Electric

• R. G. Withrow, EA Systems Manager, TU Electric

• D. R. Woodlan, Docket Licensing Manager, TU Electric

• J. E. Wren, Assistant Director QA for Administration, TU Electric

- _ - _ _ _ _ _ _ _ - _ _ _

-_ .

.

.

,

, ,

The'NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the April 4, 1989, exit meetin . Follow-up on Violations / Deviations (92702)

(Closed) Violation (445/8827-V-01): This violation concerned the failure of the applicant to maintain controlled procedure manuals-in a complete and current condition as required by the Quality Assurance Manual and specific lower tier procedure The applicant has corrected the manual deficiencies identified by the NRC. Further, the applicant issued interoffice memoranda emphasizing the need to maintain controlled manuals in:accordance with procedures. However, site surveillance of controlled manuals and the results of audit TCp 89-03 indicate that the above corrective actions have been inadequate to preclude recurrence. Based on the unsatisfactory results of audit TCP 89-03, the applicant has issued Corrective Action Request (CAR) 89-02 to address the recurring problem of ineffective manual contro The NRC inspector has reviewed Audit Report TCP 89-03, CAR 89-02, and the identified root causes and recommended preventive actions. Recommended preventive actions included:

(1) establishing one project control system for all aspects of manual control, (2) reducing the total number of controlled manuals issued, and (3) establishing consistent methods of processing changes to procedures and manual The NRC inspector determined issuance of CAR 89-02 to be an appropriate management response to the identification of the recurring deficiency in manual control. Since the applicant is addressing the deficiency at an appropriate level and the preventive actions appear to address the root causes, this violation is closed. NRC inspection of the effectiveness of the applicant's corrective actions will be assessed during '

future inspection . Assessment of Allegations (99014)

(Closed) Improper Supervisor Action (89-A-010): A Quality I

Control (QC) inspection supervisor voided the results of one QC inspector and assigned another QC inspector to repeat the l inspection and different results were obtaine The first QC '

inspector believed the supervisor's actions in voiding his inspection were wrong and that his inspection results were I vali l

- - . _ _ _ - - - -_ _

'

.

.

.

.

The QC inspector submitted this concern to both the NRC and the SAFETEAM. The SAFETEAM completed their assessment of this concern and the NRC inspector reviewed the results of this assessment. The following are the more salient points of the SAFETEAM assessmen When briefed of the concern, the Brown & Root site QA manager >

concluded that the QC supervisor's actions were consistent with the duties and responsibilities of,his position and that no procedures or instructions were violated. The QA manager did admit that the supervisor used poor judgement in the-actions he took, probably due in part to schedular pressure The QA manager counseled him and other QC supervisors on more appropriate ways of handling this kind of situation in the futur The QA manager also commended the perseverance of the QC inspector, which resulted in another review of the inspected item. This further review identified an unsatisfactory condition found by the first inspector, but missed by the second inspecto The NRC inspector found no fault with the assessment by SAFETEAM or the actions of the QA manager. While no violations or deviations were identified, a potentially significant weakness in the QA program was note In at least this instance, the pressure of schedule may have driven a first line QC supervisor to using poor judgement and a QC inspector to doing less than an acceptable job. The opportunity for similar occurrences will increase in the days ahead. No further NRC inspection of this allegation is planne . Design Changes and Modifications (35744)

During the previous inspection report period, the NRC inspector completed an inspection of the established program for the control of design changes and modifications (NRC Inspection Report 50-445/89-10; 50-446/89-10). The NRC inspector verified the implementation of that program during this inspection perio At present, all design changes and modifications are being processed in accordance with Procedure NEO 9.17, " Initiation, Review, and Approval of Design Modification Requests -

Construction Phase," and those engineering and construction procedures identified in the previously referenced inspection repor Procedure NEO 9.17 will continue to be used for all changes and modifications until Unit 1 fuel loading, at which time design modifications on Unit 1 will be processed in ,

accordance with Procedure NEO 3.03, " Preparation, Review, and i Disposition of Plant Design Modifications." In 1987, one i plant design modification was processed in accordance with j

'

NEO 3.03. The NRC inspector reviewed the document package for L _ _ - _ _ _ _ - - - -

_ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - -

.

.

.

, .

this modification, DM 87X-001, which pertained to the biocide injection system for the service water intake system. Based on this review, the NRC inspector verified the design modification was processed in accordance with NEO 3.03. The document package included documented evidence that:

interdisciplinary reviews were performed; the change was evaluated by the Station Operations Review Committee; test l

'

procedures were prepared, reviewed, and approved and the test results were presented; an FSAR change proposal was prepared; and the necessary design change authorizations (DCAs) were prepared and processed. The design modification appears to have been processed properly and should be representative of l the manner design modifications will be processed following Unit 1 fuel loadin Currently, there are three types of design changes controlled by NEO 9.17 and subtier procedures: the DCA, the DCA with confirmation required (DCA/CR), and the advanced DCA/CR (ADCR). (NOTE: One other form of design change not considered during this inspection is the nonconformance report that is used in some instances as a design change for the disposition of the nonconformance.)

The DCA is the typical form of processing a dasign chang The DCA is initiated when a need occurs. It is then reviewed by at least two levels of engineering (the responsible engineer and the supervising engineer). The DCA then undergoes an interdisciplinary review and an independent design verification. When these actions have been'

satisfactorily completed, the engineering unit manager approves the DCA for implementation. The NRC inspector reviewed six DCAs selected from late 1988 and early 1989 and found them to have been processed in accordance with the controlling procedure The project began using the DCA/CR in early 198 The DCA/CR is processed the same way as the DCA, except the interdisciplinary review, independent design verification, and the engineering unit manager approval are not completed before the DCA/CR is released for implementation. The DCA/CR is to be used only in support of ongoing field activities, in which case, confirmation must be completed within 60 days following its implementation. The following are exceptions to the 60 day time limit for confirmation: (1) the DCA/CR will not be confirmed if it is superseded by the next higher revision; (2) the DCA/CR documents an approved temporary modification; or (3) the DCA/CR is part of an approved validation program or a design reconciliation program in which case the DCA/CR may be confirmed at any time prior to validation or reconciliation of the design in which it is included. By the close of this inspection period, approximately 15,500 DCA/CRs have been issued with just under 90% being associated with a

_ _ _ _ ___ __._ _ ____ ________ _ ___j

t

'

--o e

'

>

,

reconciliation or validation program. The other DCA/CRs, just over 10% of the total, require confirmation to be or have been completed within 60 days of their implementation; i.e.,

construction associated with the DCA/CR is complet The project began using the ADCR in December 198 If the design change is needed immediately by construction, the designated engineer authorizes the use of the ADCR. The ,

responsible engineer then has one shift (up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) to i complete the processing of the design change which is then issued as a DCA/CR. From this point, the ADCR becomes a DCA/CR and continues through the process as described abov The NRC inspector selected 14 DCA/CRs to verify they were processed in accordance with the controlling procedures. The NRC inspector did not find any. instance where the procedures were not_followed, but did identify several weaknesses with the procedures as they were implemented. These are: The use and control'of the DCA/CR is not described in the methodology of the validation or reconciliation program When the DCA/CR relates to an ongoing validation or reconciliation program, the applicable program is not identified on the DCA/C Where the 60 day requirement for confirmation is applicable, the 60 days do not begin until construction is complete. The NRC insp ctor believes 60 days is too long for the completion of engineering activities, and the time required to complete the confirmation should begin when the DCA/CR is released to construction, not when construction is complet The criteria for controlling misuse of the DCA/CR do not provide adequate assurance that there is an extremely high probability the DCA/CR will be subsequently confirmed by engineering without compromise or loss of design margin; e.g., the DCA/CR is sufficiently similar to, or the same as, a previously reviewed and approved design chang The log-in time and the log-out time for the ADCR is not clearly documented so compliance with the one shift limit can be monitored or verifie Engineering management is currently reassessing the procedures controlling the DCA/CR process in light of the above observations. This matter will be considered an open item

until this assessment is complete (445/8818-0-01; 446/8818-0-01).

i

_

_ - . . _ - _ .

F a ,

,

, .

The NRC inspector also reviewed two Engineering Assurance Surveillance Reports (EASR 88-78 and EASR 89-73). These surveillance assessed the effectiveness of the engineers making design changes and the interdisciplinary review These reports appear to have provided useful feedback and improvement to the engineering personne The operations program for controlling lifted leads and the ,

use of jumpers was also inspected by the NRC. Procedures l STA-602, " Temporary Modifications," and STA-605, " Clearance and Safety Tagging," were found to provide the administrative cc trol for these activities. The NRC inspector reviewed the Temporary Modification Log and Tag List. The status and supporting documentation for four open temporary modifications were reviewed. Four control room cabinets were also inspected by the NRC inspector; Service Water System cabinet, solid state safeguards cabinet, solid state isolation equipment cabinet, and a diesel generator control cabinet. Tags subject to the control of STA-602 and STA-605 were found in these cabinet No items of noncompliance were identifie In cummary, during this and the previous NRC inspections, the design change and modification program for construction and subsequent plant operation has been inspected. No violations or deviations were identified. One weakness was noted concerning the use and control of DCA/CRs. . Engineering management has initiated a reassessment of the process. The NRC inspector will inspect the results of this assessment and any actions during a future inspection period. This matter is being tracked as an open ite . Procurement, Receipt, Storage and Handling (35065, 35746, 35747)

During this report period, the NRC inspector reviewed the applicant's program relative to the procurement, receipt, storage, and handling of vendor supplied equipment and material. The review was performed to assess the effect of recent changes to the procedures providing control of these programs. The review also assessed the adequacy of the implementation of these procedure The activities for procurement, receipt, storage, and handling of safety-related equipment and material are performed primarily by TU Electric with the exception of ASME Section III activities performed by the constructor, B& The NRC inspector reviewed procedures, purchase orders (POs),

receipt inspection reports, QA verification plans, and results of vendor audits. Additionally, the NRC inspector toured warehouse storage areas and interviewed personnel responsible for the development of procurement packages, performing

!

1

h- - - ,

". .

~

h, -

b

.

i~e' ,

'

.. 9

.

receipt inspection, and the storage and handling of received-item '

p TU Electric procedures reviewed were:

Jg NEO 3.05 Reporting and Control'of Nonconformances NEO'3.14 . Evaluation and Verification of. Vendor Activities NEO 5.19 Review and Control of Vendor Documentation.

i NEO 6.02 Preparation and Revi'ew of Procurement Documents NQA 3.07 QA Audit Program NQA 3.09-11.03-Receiving Inspection NQA;3.14 ' Control of Vendor Activities NQA 6.02 Quality Review of Procurement Documents-B&R' Procedures reviewed were:

AAP QA Review of Procurement Documents g AAP Evaluation and Selection.of Suppliers-AAP Source Surveillance AAP 1 Controlling Nonconforming Items ACP Identification,. Issuance and Control of Items ACP 1 Storage and Maintenance of Mechanical Equipment AQP 1 Receiving Inspection AQP 1 Storage and Maintenance of Equipment Inspection H The NRC inspector also reviewed other site procedures, such as those found in the site warehousing manua The NRC inspector determined that these procedures provide for: (1) the development and maintenance of an approved vendor list; (2) the development of procurement specifications and purchase orders with appropriate technical and QA requirements;-(3) the identification of critical

_ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _

_ _

_ . _ _ _ _ _ _ _ _ _

'

t ..

, , 10

,

characteristics; (4) the development of verification plans to assure critical characteristics are being met; (5) control of warehousing and rse. Apt inspection activities, including controlled storage levels and provisions for identifying nonconforming materials or components; and (6) identification of storage life and special handling instruction Additionally, the NRC inspector reviewed site procedures for the surveillance of storage areas and the identification of maintenance requirements for stored items. The implementation l of the above surveillance and maintenance programs was inspected by the NRC inspector during NRC inspection of Issue-Specific Action Plan (ISAP) VII.a.9, " Adequacy of l'

Purchased Safety-related Material and Equipment." Results of the NRC inspections were documented in numerous NRC inspection reports and were, in general, favorabl Notable changes to the current-procurement, receipt, storage, <

and handling programs include: (1) the restructuring of the f construction receipt program to conform to the requirements 1 imposed on the operations receipt program, (2) the identification of critical characteristics, and (3) the development of verification plans for use by procurement QA to '

assure that critical characteristics were me To assess the implementation of these changes, the NRC inspector reviewed six recently issued POs, the technical and quality assurance requirements, and the verification plans developed to assure the adequacy of the procured items. The Pos reviewed included items such as isolation modules from  ;

Forney Engineering and the contact block and cover kit for {

certain limit switches. PO numbers inspected were- 1 I

665-71382 665-71393 I 665-71303 665-71359 665-71375 665-71292 These safety-related POs were reviewed to verify that:

(1) specific identification of the procured item was included; (2) special test, inspection or handling requirements were f I

identified; (3) access to the supplier's plant and records were required; (4) documentation, such as installation manuals, drawings, or nonconformance reports were required to  !

be provided by the supplier; (5) the imposition on the suppler of the applicable criteria of Appendix B to 10 CFR 50; and (6) compliance with the retirements of 10 CFR 21 including posting of 10 CFR 21 reporting requirements was included. The 1 NRC inspector determined that the above requirements were j included in each PO and that an approved vendor was use The NRC inspector reviewed POs issued to vendors not on the l TU Electric approved vendor list (AVL). The NRC inspector l l

I

- . - . . _ - _ _ _ - _ _ _ _ _ - _ _ _ _ . - _ _ _ _ _ - _ - _

L ~+

L '

. .

..

. .

determined that the POs were issued in accordance with the requirements of the TU Electric commercial grade procurement program with proper subsequent dedication as nuclear safety related. . (See NRC Inspection Report 50-445/89-03; 50-446/89-03 for review of commercial grade procurement.)

To assess the adequacy of vendor audits performed to maintain the AVL, the NRC inspector reviewed two recently performed vendor audits, TBG-89-06 of a pump manufacturer, and TWS-89-02 of a supplier of weld filler material. The NRC inspector's review of.these audits showed that both suppliers had previously been assigned to the TU Electric AVL and that the audits were being performed to determine if the supplier should continue on the AVL. Accordingly, the audits were programmatic in nature, that is they were performed to determine if the supplier was adequately implementing a QA program in accordance with the applicable portions of 10 CFR Part 50,. Appendix B. The NRC inspector reviewed the audit l

!

check lists, the evidence verified, and the audit result The NRC inspector determined that the aut_ts had been performed to an appropriate depth and had reached proper conclusions as to each supplier's compliance. Each of the suppliers retained their " active" status on the TU Electric AV In summary, based on review of procedures for procurement, receipt, storage and handling, the applicant has developed a procedural program adequate to prescribe and control these activities. Additionally, based on review of vendor audits, procurement documents, receipt inspections, and warehouse storage areas, the applicant appears to be adequately implementing the prescribed progra No violations or deviations were identified during the inspectio . Review of Procurement Programs for Nonconformance Control and Conditional Release (35746, 35747, 35065)

!

During this report period, the NRC inspector reviewed the i applicant's procedures for nonconformance control and for the conditional release of nonconforming items. The review was performed to assess the adequacy of recent revisions of these .

procedures and to verify that the procedures continued to I provide: (1) requirements that nonconforming items be i identified and controlled and that nonconforming items be marked or segregated to prevent inadvertent installation or use; (2) requirements that dispositions of nonconforming items l be performed by the responsible organization; (3) provisions for notifying affected organizations; and (4) provisions by which documentation concerning nonconforming items is ]

considered by the applicant's audit group for supplier

_ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ l e-r -

$

.o

, . .

evaluation. Additionally, the NRC inspector verified that the controls for issuing a conditional release provide:

(1) appropriate documentation; (2) designation of authority to issue the conditional release; (3) justification for use; and (4) the imposition of appropriate precautions or limitation The NRC inspector determined that NEO Procedure 3.05,

" Reporting and Control of Nonconformances," Revision 6, continued to provide the above' requirements and provisions; however, significant changes were implemented by these revisions. Revision 5 of NEO 3.05 required that, prior to installation or operation of nonconforming component, a conditional release was required. Revision 6 limited the requirement for obtaining a conditional release to uninstalled nonconforming items only. This change, along with other changes to the procedures, allowed specific startup and operations personnel to determine the need for the operation of a nonconforming component. The NRC inspector recognizes that personnel such as the assistant startup manager and the shift supervisor are knowledgeable and qualified to evaluate the impact of a nonconformance on the performance of installed, equipment or material; however, procedure NEO 3.05 did not address: (1) the assessment of_ precautions and limitations for the nonconforming item; (2) guidance as to when input from engineering was required; and (3) which department (i.e.,

construction or operations) was responsible for completion of i the NCR. The NRC inspector believes the inclusion of these aspects for NCR processing would enhance the program. The NRC inspector has discussed these items with the applicant and was informed that the applicant was reviewing Procedure NEO 3.05 and would consider them during that revie Future NRC inspection of the nonconformance control program during startup and operations will further assess the effectiveness of'the implemented progra Since ASME related components have specific QA requirements, the NRC inspector reviewed the procedures to verify that ASME requirements were addressed. Procedures NEO 3.02 AND 3.05 contain provisions that require that ASME QA program requirements be complied with if applicabl Typically, B&R Procedure AAP-16.1, " Controlling Nonconforming Items,"

provides the details by which ASME Section III related nonconformances are addressed. The NRC inspector reviewed AAP-16.1 and determined that ASME Section III requirements are adequately addressed. The NRC inspector reviewed the other changes to these procedures and determined that they also were acceptabl While Procedure NEO 3.05 does not specifically provide for notification of receipt inspection deficiencies to the TU Electric vendor evaluation group, Procedure NQA 3.07,

" Quality Assurance Audit Program," requires that audit

!

1.

L _ _ _---

r -

-

, . >.

'

l

, . .

!

i preparation include a review of trend results and sendor ratings. Vendor ratings'are controlled by NQA 3.le, " Control of Vendor Activities." Deficiencies noted by receipt inspection are an integral part of the vendor rating and as such are considered during vendor audit preparatio No violations or' deviations were noted during this revie . Applicant Meetings (92700)  ;

The NRC inspector attended applicant meetings concerning site ,

activities and implementation of various site program Meetings attended during this reporting period included the QA ,

'

Overview Committee meeting on March 21, 1989, and a public meeting on March 17, 1989. These meetings reflect management's involvement in day-to-day activities and attention to potential problems. No violations or deviations were identifie At a public meeting held March 17, 1989, at the CPSES '

Engineering facility, the applicant presented the CPSES program for room and area walkdowns performed to verify that rooms and areas.were construction complete prior to turnover to Operatien Among others, the meeting was attended by:

W. G. Counsil, W. J. Cahill, Jr., John Beck, H. D. Bruner, A. B. Scott, D. Reynerson, J. W. Muffet, D. E. Devinney, representing TU Electric senior management and the site departments of construction, engineering, operations and QA; E.-J. Ottney, program Manager for CASE; R. F. Warnick, R. Latta, M. Runyan, P. Stanish, and others representing the onsite NRC staff. After the presentation, TU Electric answered questions from the NRC staff and from CASE. The NRC expressed their intention to inspect the program as it developed to verify that the program provided necessary assurance that rooms and areas were construction complete and that identifiable deficiencies were documented for correctio The result of the NRC inspections will be reported as those inspections are complete . Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. One open item was disclosed during this inspection as discussed in paragraph . Exit Meeting (30703)

An exit meeting was conducted April 4, 1989, with the applicant's representatives identified in paragraph 1 of this report. No written material was provided to the applicant by

__

~

r _

,

p, .::, ; , >

.

"

ljr; l* ' ,

4 '

(; . ;. : : . .. *

.

.

ce ,

s

'the inspector?during this reporting period. . The' applicant.did

[- notiidentify'as' proprietary.any of the materials provided to 4 -

or reviewed by'the inspector during this inspection.- During g-y . Js '

~:this meeting,'the NRC inspector summarized the. scope and

.

-

-

findings of the inspectio ,

>

t y

?.

r

..

b

L w' . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ - _ _ _ .__ __ _ _ _ _ .

NACFoaans U.S. NUCLEAR REGULATORY COMMISSION enwoPA wwCroamm o' wir .eaa = an a.e P* INSPECTOR'S REPORT d- '

alvitWla Office of Inspection and Enforcement H. LIVERM0RE iN SPE C10a 5 ~

C omt. TA CTS : a". B ne uioaaAu ---

LinNsmviN00a ' a '*,,

5,^ c ' ** 00C o ,NO ,,,,,,,,0aL,CE,,st a:P N .?i s,EC 0:

No rev P400VCYis13eg.ess No 54$ MO vc

'-*5'"'

TU ELECTRIC X 0 5 0 0 0 4 4 5 qq t g

" - "00* '

COMANCHE PEAK STEAM ELECTRIC _ n 5 0 0 0 4 4 6 3 9 I 52 o RTATION _

0 - 08'87E c

a - AEPLnct g 1 2 14 il 16 PEACD OF aNytSisGATCN/INSPECTCN IN SPEC fiON PE A F0augo g v OnGANi2ATON (CCE (* REGsONiMO CON 09 Fnou 70 1 - REGIONAL OFFICE STAFF OfMgm '

,

M Day vn MO DAY YA

)( 2 - Ri$lotNT INSPICTOR

_ AtGCN N5iiW BAANCM o 13 olS 9 19 olv ol4 BI9 8-""'""^*"^""5^'"^*

4 '

C C C 3 3 31 1 32 33 34 35 AtGCNAL ACTCN TYPE OF ACitytTV CONDUCYtoicheca one tes onwvi 4 Check one boa ordel X 02 - SAFETV 06 - MGMT visit to - PLANT SEC

_ 14 - shouinv 1 - NRC FORM 541 03 - =ClotNT 07 - $PECiAL 11-lNVENT vtR 16 - INvtSTIGAfiON X 2 - AECCNAL OFFICI LETTgn 08 - ENFORCEMENT 08 - VINDOR

~ 12 - $MiPMENTitmpon?

06 - MGMT AU0i? 08 - MAT ACC iMPCai r- - *

3 ,e 37 3 IN5PtGTg vEgTiG T FINQiNG5 70f AL NUM814 (NF0mCEMENY CONFERENCI atPORf CONTAIN 2 m 0F vCLATON$ AND MELD INFORM A f CN Lif f ta cP al P04T ia AN5Mitf AL DAf f C 8 C 0 0(vtAfsONS NmC F0asa sees aEP0afSENT X X 1 - CLEAR Om ats 70 M0 F0a 2-vCutCN LETTiallluto ACTCN 3 - 0(VIAfs0N A e C 0 A e C 0 A e C 0 M0 DAv vn MO OAv va 4 - VIOLATCN & OtviAf s0N , , , , i - vis i t . yis l l l l l l n , - =~- 0i a o o .0 M00VLI INf oa MA f CN M00vtt %s0aMAvCN MODULE NUM8ER INSP yg g M00VLt og0 FOLL0wvP M00vig NyNIS E A IN18

-

5 se r - { MODULE ago s0LLowy

. .

1 a . 3

- . . . - . g is r !!! ! ! !! il

.

!I

- .

I 8

. s!i i  ! i l l!!!!  ! : l ! !! !I ! ! ! !!!!! !!!  !! !! !!  !

e i 2 3iOl7:0,3lB '

oin z ii i li,l f 2 36lor(C>1sh . ^

09 6 libio E  : Iiil

'

i i i i i liil '

oiSi% / rCi oA_ i liil

1 i i f I ll I l '

I i 1 1 f ll I l

___

ee t I i ll l 0 1 1 1 e i __ 1 lt t l

e 2 2 9lEf7tol2.l- Dili9 i e l ll l l sf 3 5l71'I14l8 '

0131% /to n o .c _ i liil

Di l l) : t t lt i ! '

o4 f7 I1010 O i lt i !

11 I i l lt i ! '

f e i 1 __ 1 l1 1 l o

. , , , i l,,1 0

, , , , -. , I,,1 gp og ^

e f / #4l B 0 11 i ll , l f d2 G l7,S1(ol 8 ^

C

,

e i e BIO 19 /1 010_ i liil l De t il i t i ll 1 l '

B1019 /tonC., I ll 1 l f f i i i l i I I f f I t 1 i i t 1 I i i i t t i f i i p 2 9 g_ l7,0, cj - A o ,0,g l,,l ,8 py

. , , , , gl7,,,.7 l g A e,,,, , ,o ,g) c ,l,,l DD3 l 1 1 t f f i '

Dl! f ( [l hO C f lI i l

'

l I i e i l l l l l t i l i 0 CECLE StoutNCE IF g l VOLATION OR DEVIATON i, e i * ' l 3 i e

(' '

-

. _ _ _ _ - _ _ - _ _ - - _ -

.

,,) ,*.-

"o *

.-

RP OSI6B

'-

SALP FUNCTIONAL AREA ASSESSMENT AND PRELIMINARY IN

.. .. l* Facility: C M S $ GL Inspection Report No.: so/ so/v%.S~ 23-IS vA 99 - t 9 l FUNCTIONAL AREAS l PMNT OPERATIONS I / I l I I 11 l l 1 l III I IV I V l Dev lunitlRatinal l l l l l l l l l l l 1 l l RADIOLOGICAL CONTROLS I l l- l l l l l l l l l l l l_ I I l l l l l I l i l MAINTENANCE l l l l l l l

!

l l 0l i I I 1 l l l l pg l SURVEILLANCE * l l l l

l 1 I I l l El l l l' l l l l l l l RI l FIRE PROTECTION l l l l l l l l l l Al l I I I i l

i l

l

l l

l l Tl l EMERGENCY PREPAREDNESS l l 11 l l l l l l l l l l l 1 1 I l 0l l-l SECURITY l l l 1 I I l l Nl t'

!

l' I l 1 l

I I l l I

l l l l Sl I i 1 l OUTAGES l l l l l l l l l l l l l __l_l

-

l 1 1 I I I l QUALITY PROGRAMS & ADMI * I I l

'

l l -l l l l l l *

l_ CONTROLS AFFECTING OVALITY IM i l i I I I I l

2 ll l LICENSING ACTIVITIES *

l l I

l l l l l *

l l l l l l l l l-l TRAINING & QUALIFICATION * 1 i I I l l l l l l l l *

l EFFECTIVENESS l l l

I I I I I 1 l SOILS AND FOUNDATIONS 1 I I l l

l_

l l

i I l l l l l l l l l l--l ('lI CONTAINMENT, SAFETY-RELATED l l l l I I I i l Cl

__ STRUCTURES & MAJOR STEEL SUPPORTS' I I I l

I l l i

l l l 0l l PIPING SYSTEMS & SUPPORTS l l l I l l l Nl l L I I I l

I l

I l

I I l l l Si l SAFETY-REuTED COMPONENTS I l Tl I l l l l l_ MECHANICAL l l l l l Rl I I I I I l AUXILIARY SYSTEMS l l l I I I l l Ul l l l l l l l l l l l Cl l ELECTRICAL EQUIPMENT l

l l lAND l CABLES l

l 1  ! I t l Tl

'

l_ l i I I I l

I t l 3 l II l INSTRUMENTATION I l l l 0l l l l l l Nl

'

l l l l l

'

l l l 1 1 I I l l 1

• Functional areas for Construction and Operations l ~~~~ l CRITERIA FOR DETERMINING CATEGORY RATING Management Involvement in Assuring Qualit . Approach to Resolution of Technical Issues from a Safety Standpoin Responsiveness to NRC Initiative . Enforcement Nistor Operational and Construction Event . Staf fing (including management).

RATING KEY: (For Categories 2 - Declining and 3, provide narrative basis for conclusion)

Category 1 Category 2 Category 2 - Declining ,

Category 3 l ,

l l Inspector (s) concerns adequately addressed or

'

l,7_ Inspection Evaluption Form being processe _

/-/ -j p 9 Lead Inspecto ,6 o '

(${gpature)

_

Section Chie M42 L (Date) (Signature) (Date)

March 3, 1986

- _ - _ _ - _ - _ - _ - - - - _