IR 05000445/1989046

Insp Repts 50-445/89-46 & 50-446/89-46 on 890607-0705.No Violations or Deviations Noted.Major Areas Inspected: Applicant Actions on Previous Insp Findings,Plant Procedures for Operations & Applicant Meetings

ML20247C655
Person / Time
Site:	Comanche Peak
Issue date:	07/19/1989
From:	Hale C, Livermore H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247C652	List: IR 05000445/1989046 ML20247C646
References
50-445-89-46, 50-446-89-46, NUDOCS 8907240405
Download: ML20247C655 (13)

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l U. S. NUCLEAR REGULATORY COMMISSION

UFFICE OF NUCLEAR REACTOR REGULATION 1.

l NRC Inspection Report: 50-445/89-46 Permits::CPPR-126 l 50-446/89-4 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 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 Cenducted: June 7 through July 5, 1989 Inspector: > ~

/Y J. g e, Reactor Inspector * Datie Consultants: J. Birmingham, RTS (paragraph 3)

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Reviewed by: _

H. H. Livermore, Lead-Senior inspector Date ff o (,,

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Inspection Summary:

r Inspection Conducted:_ June 7 through July 5, 1989 (Report

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50-445/89-46; 50-446/89-46)  !

Areas Inspected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings, plant procedures for operations, and applicant meeting Results: Within the areas inspected, no violations or deviations were identified. Both strengths and weahnesses were noted during the inspection of plant procedures for operations. These are discussed in paragraph ._ __ - -

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DETAILS Persons Contacted

• J. L. Barker, Manager, ISEG, TU Electric

• R. A. Berry, Licensing Manager, CECO l

• 0. Bhatty, Issue Interface Coordinator, TU Electric  !

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• M. R. Blevins, Manager of Nuclear Operations Support, TU Electric

• H. Bruner, Senior Vice President, TU Electric

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

• H. M. Carmichael, Senior QA Program Manager, CECO

'D. J. Chamberlain, Licensing Lead Engineer, Unit 2, CECO

• J. T. Conly, APE-Licensing, SWEC

• W. G. Counsil, Vice Chairman, Nuclear, TU Electric

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

• D. E. Deviney, Deputy Director, Quality Assurance (QA),

TU Electric

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

• J. L. French, Independent Advisory Group

• E. H. Gant, Executive Assistant, TU Electric

• J. Greene, Site Licensing, TU Electric i

• 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, Chief Manager, TU Electric

• J. J. LaMarca, Electrical Engineering Manager, TU Electric

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

• D. M. McAfee, Manager, QA, TU Electric  !

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

• E. F. Ottney, Program Manager, CASE

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

• W. J. Parker, Project Engineering Manager, SWEC/ CECO

• P. Raysircar, Deputy Director / Senior Engineer Manager, CECO

• H. Schmidt, Director of Nuclear Services, General Division, TU Electric

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

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

• R. L. Spence, TU/QA-Senior Advisor, TU Electric

• W. L. Stendelbach, Executive Assistant, 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 The NRC inspectors also interviewed other applicanc employees during this inspection perio * Denotes personnel present at the July 5, 1989, exit meetin _ _ _ _ - _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _

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f Applicant's Action on Previous Inspection Findings-(92701) (Closed) Open Item (445/8918-0-01; 446/8918-0-01):

Procedural weaknesses were identified in the control'and.

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,- use of design' change authorizations with confirmation-

. required (DCA/CR): (1) methodology not described in the validation and, reconciliation programs;-(2) th validation or. reconciliation. program, if applicable, was not identified;on.the DCA/CR; (3) the 60 days for confirmation was too long and did not begin until construction was complete; (4) the criteria permittin DCA/CR use lacked, specificity, and (5) the one-shift time limit for. processing the advance DCA/CR (ADCR) could not be effectively monitored or verifie Five validation and reconciliation programs are involved in the use of DCA/CRs: pipe supports, cable tray hangers, Train A and B conduit supports,.I&C supports, and heating, ventilation, and' air-conditioning (HVAC)

supports and ducts. For pipe supports involving vendor:

certified drawings (VCDs) Procedure ECE 5.05-03, " Pipe-Support Drawings and. Pipe Support Location Isometrics,"

provides the requirements for the associated DCA/CR confirmations. The DCA/CRs are confirmed in conjunction with the revision of the affected VCD. Per Procedure ECE 5.05-03 the revision of a VCD requires.the same review process that is required for DCA/CR confirmation. With few exceptions,.however, each DCA/CR will be confirmed individually. Activities associated with field verification methods (FVMs) is essentially complete, particularly with respect to initiation of further DCA/CR If further FVM related DCA/CRs were to be initiated the FVM will be noted in Block 7.b and the DCA/CR will be individually confirmed. For those DCA/CRs that are still inprocess, that is not confirmed, when they are confirmed the related FVM will be noted in Block 7.b, if not already note All the DCA/CRs not specifically associated with one of these five validation or reconciliation programs must be processed (confirmed)

within the time requirements established for-confirmation.

l Procedure ECE 5.01-03, " Design Change Authorization," was revised to require the following: (1) DCA/CRs shall only

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l be used to authorize simple design changes in direct L support of ongoing field activities, and the work package will be clearly identified on the DCA/CR in Block 3.c; and (2) except in the case of those five programs described in the previous paragraph, DCA/CRs are required

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to be confirmed within 30 days of their originatio Other enhancements were also included in this revision such as various methods for engineering management to monitor for abuse-of the DCA/CR proces Also included in the revision of ECE 5.01-03 was a requirement that a weekly status report on ADCRs be provided by the Engineering Support Manager to all discipline managers. These engineering managers are required to monitor ADCRs and assure they are processed and issued as DCA/CRs within the allotted eight hour time limi The NRC inspector has been monitoring the processing status of ADCRs and DCA/CRs for the past several week Since the revision of ECE 5.01-03, changing the confirmation time requirement from 60 days to 30 days, the backlog of DCA/CRs exceeding the 30 day confirmation requirements has been large, but steadily decreasin This is due in part to the recent procedural requirement chang The ADCRs exhibit a similar problem: a continuing failure by engineering to process these documents within the required time constraints. The NRC inspector discussed both these concerns with engineering management. Engineering management has elected to discontinue the use of the ADCR effective July 10, 1989, which solves one problem. Engineering management has also committed to concentrate their efforts to eliminate the.DCA/CR backlo In the coming weeks the NRC inspector will continue to monitor their efforts in this area, treating this matter as an open item (445/8946-0-01).

The actions described above form the basis for closing this open ite b. (Closed) Open Item (445/8925-0-01; 446/8925-0-01):

Evaluate the surveillance team's conclusions and proposed corrective actions resulting from their inspection of the document and record control of Brand Industrial Services, Inc. (BISCO).

Construction surveillance CS-89-0165 was completed May 9, 1989, and the report was issued May 24, 198 The results of the surveillance indicated that BISCO procedures were inadequate for the identification and the processing of seal installation and inspection documents and record In response to the surveillance findings, BISCO committed to the following actions in their letter to TU Electric dated June 24, 198 _ _ _ _ _ _ _ _ _ - _ __-__-________-__a

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I Revision of Procedure QCP-102, " Traceability Methods and Recording," to: (1) define the process for transposing information from the field copy of the Internal Work Release (IWR) to the permanent IWR; (2) provide guidance for transfer of information and disposition of the field copy of the IWR; (3) describe the responsibility of individuals who do this transfer and add a signature and date block; and (4) provide a method for authenticating documents by authorized personnel. Procedure DC-2A,

" BISCO Records Management and Turnover of Records to TU Electric," will also be revised to provide a reference to the forms used during the' processing of documents.and record BISCO has committed to complete these actions by July 14, 198 Concurrent with BISCO's revision of these procedures, Construction Surveillance is reviewing the changes to assure they are responsive to the identified problems. The actions by BISCO and Construction Surveillance complete the item and it is close . Plant Procedures for Operations (42400, 42700)

This NRC inspection was performed: (1) to confirm that the existing plant procedures system is adequate to control safety-related operations, and (2) to determine the adequacy of management controls in implementing and maintaining a viable procedural system. These objectives were accomplished by: (1) a review of those procedures which provide the administrative controls for the issuance and maintenance of operations procedures, (2) a review of the scopes of operations implementing procedures to verify that the essential elements of the operations program are addressed, and (3) a detailed review of a sample of implementing procedures to assess compliance with administrative control The CPSES procedures for operations have been previously inspected by the NRC and reported in NRC Inspection Reports 50-445/84-15; 50-445/84-21 and 50 445/84-31. Those NRC inspections results found that, in general, plant procedures for operations were acceptable and met regulatory requirements; however, several violations, deviations, unresolved, and open items were identifie These items were subsequently addressed by the applicant and have been reviewed and closed by the NR The applicant's current procedural program for plant l

operations has, in many areas, been revised since the above NRC inspections. Therefore, this inspection focused on

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assuring that the basic program continued to meet regulatory requirements and that program revisions did not decrease program complianc !

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The CPSES FSAR commits to an operations program that is in accordance with the guidance of USNRC Regulatory Guide 1.33,

" Quality Assurance Program Requirements (Operations)."

Regulatory Guide 1.33 essentially endorses ANSI N18.7 and ANSI N45.2 and provides a listing of typical safety-related operation's activities to be prescribed by written procedure The applicable clements of the above ANSI standards and Regulatory Guide were utilized as the basis for this inspectio The CPSES procedure control program is divided into three areas: activities under the control of the Startup and Test Department, Nuclear Operations Department, and the Nuclear Engineering and Operations Group. Each of these areas has administrative procedures that prescribe procedure control'and maintenanc The current site Startup and Test Department consists of both a startup organization and a test organization. The activities of the startup organizations that are preoperational in nature were not included as part of this inspection. Those activities of the test organization that fall within the control of the Nuclear Operations were included. Procedures for this area consisted primarily of Test Department Administrative (TDA) procedure The CPSES site procedure program provides a set of upper tier procedures entitled, the Nuclear Engineering and Operations (NEO) piocedures. The NEOs provide policy and guidance to govern the activities of the four main divisions of the NEO grou These four divisions are: (1) Nuclear Operations, (2) Engineering and Construction, (3) Nuclear Engineering, and (4) Suppor The NRC inspector reviewed the following NEO procedures to assess the adequacy of those procedures to provide appropriate administrative control NEO 1.01 " Organization of the Nuclear Engineering and Operations Group" (Revision 2)

NEO 1.02 " Scope and Function of the Nuclear Engineering and Operations Policies and Procedures Manual" (Revision 5)

NEO 1.03 " Format and Content of Nuclear Engineering and Operations Policy Statements and Procedures" (Revision 6)

NEO 1.04 " Preparation, Issuance, and Control of Nuclear Engineering and Operations Policy Statements and Procedures" (Revision 7)

NEO 2.01 " Operations Review Committee" (Revision 1)

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NEO'3.03- " plant Design Modifications" (Revision 3)

NEO 3.07 " Quality Assurance Audit Program" (Revision 2)

NEO 3.12 " Safety Evaluations" (Revision-1)

In addition to-the above procedures, other NEO procedures dealing with operations activities such as: security, reporting of nonconformances, control of radioactive waste,

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health physics, and changes to the site technical specifications or the FSAR were also reviewe The NRC inspector determined that the above procedures provided administrative guidance _for the preparation, approval, controlled distribution, and maintenance of procedures affecting operations that was appropriate for the level of control provided by the NEO's. Strengths noted in the review of the above procedures were: (1) consistent requirements for procedure format and content, (2) references to both interfacing procedures and to source documents, (3) controlled use of figures and attachments to procedures, and (4) requirements for periodic review of procedrres'to assure that the procedures were updated to current plant condition The NRC inspector noted that NEO 1.04, the procedure for the preparation and issuance of NEO procedures, did not require that an assessment of procedural changes be performed to

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determine if training of personnel to the procedural changes

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was required. A discussion with applicant personnel indicated that the training assessment is made and time allotted prior to the effective date of the procedure to allow for training.

l Review of training records by the NRC inspector supported the applicant's response, but the lack of a requirement for the i

assessment of training needs is considered to be a weakness in

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the progra The NEO procedures require that each department develop, as necessary, procedures that implement the policies and requirements of the NEO procedures.- The Station Administration Manual (STA) and a specific set of subtier manuals implements those requirements for the Nuclear Operations Department. The NRC inspector reviewed selected STA procedures to determine that they provided: (1) a description of the nuclear operations organization and assignment of responsibilities for nuclear operations activities; (2) a procedural reviet and approval process that complied with the requirements of ANSI N18.7 and 10 CFR 50.5 as defined by the CpSES technical specifications; (3) controls for the development, format, and content of procedures to prescribe nuclear operations activities including temporary procedures and shift orders; (4) a controlled process for

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procedure distribution, maintenance, and deletion when appropriate; and (5) assuring that changes to procedures are reviewed for the applicability of training. The NRC inspector reviewed the following STA procedures to determine if the-above requirements were include STA-101 " Nuclear Operations Organization" (Revision 6)

STA-202 " Administrative Control of Nuclear Operations Procedures" (Revision 17)

STA-203 " Control of Nuclear Operations Procedure Manuals" (Revision 13)

STA-205 " Changes to Procedures" (Revision 11)

STA-207 "Special Orders, Night Orders and Management Memoranda" (Revision 5)

STA-212 " Nuclear Engineering (NUC) Procedure"

-(Revision 10)

STA-306 " Nuclear Operations' Document Control" (Revision 12)

STA-401 " Station Operations Review Committee (SORC)"

(Revision 15)

STA-707 " Safety Evaluations" (Revision 4)

Based on review of the above procedures and a review of the scopes of other STA procedures, the NRC inspector determined that, in general, regulatory requirements and industry standards were addresse The NRC inspector found that the following areas were poorly defined or not addressed by the STA procedures:

. Requirements to assure that the need for training is assessed and provided prior to the issuance of procedures or procedural changes, as necessar ,

. Requirements to assure that changes to procedures are assessed for impact on other procedures or instruction . The details of the criteria to be considered during the performance of a technical review are not specified by STA-202, nor are they expressed in Attachment 8.B of STA-202 which provides the guidelines for a technical review.

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. Guidance concerning the procedure review process such as: )

(1) the criteria to be considered during such reviews, i and (2) _the method by which comments from qualified i reviewers are documented and resolved during the review process. These details are necessary to assure that a satisfactory review is performed in accordance with Regulatory Guide 1.33 and ANSI N1 The NRC inspector discussed the above concerns with applicant personnel assigned by the Nuclear Operations Support-Manager and considers these items to be weaknesses in the plant procedures progra The NRC inspector reviewed procedures from the Test Department Administration (TDA) Manual, the Operations Department Administration (ODA) Manual, and the CPSES Training (TRA)

Manual. These procedures were. determined to be in accordance with the content and format requirements of STA-202 and to l

have been reviewed by the SORC as indicated by the identification of the SORC meeting number on the cover pag The NRC inspector's review of the TRA Manual indicated that TRA procedures typically designated, by job title, the person responsible for identifying the training needs of a department or group. That person was also responsible for assuring that required training was performed and maintaine For example, TRA-311, " Test Department Qualifications," assigns to the Manager of the Startup and Test Department the responsibility for identifying training requirements and for developing and implementing a training program for the Test Departmen Additionally, TRA-311 provides a list of procedures and documents which must be reviewed by individual test engineers prior to performance of quality-related activities. The procedure list also identifies'those procedures for which retraining would be required if the procedures changed. The NRC inspector determined that TRA-311 did not provide the details of: (1) how training to procedure revisions was to be accoreplished, (2) what type'of training should be used, and (3) whether the training to procedure revisions had to be

! accomplished before the revision became effective. This I observation was discussed with the CPSES Performance and Test t Manager and the Administrative Support Supervisor. The NRC inspector learned that the revision training was being performed and was tracked manually within the department; however, no procedure or instruction existed to control that process or to provide requirements, such as the type of training to be provided and the timeliness of that trainin The NRC inspector considers the lack of a procedure to control the training process to be a program weakness and to be the results of the above noted lack of guidance for training programs found in the STAS and NEOs.

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The NRC inspector reviewed the scope of operations procedure

- manuals as identified by STA-202. These manuals covered such areas as: plant operations, security, emergency response, alarm conditions, control of radioactivity, maintenance, refueling, technical support, chemical and radiochemical activities, measuring and test equipment, and plant startup, operation, and shutdown activities. The above review was i

performed in a general manner to verify that the CPSES operations procedure manuals addressed the areas of plant f activity identified by Appendix A of Regulatory Guide 1.3 The NRC inspector was satisfied that the operations manuals did address those activities. The NRC inspector reviewed MDA-201, " Maintenance Department Procedures," and also Mechanical Maintenance Instruction MM1-801, "Borg-Warner Check Valve Inspection." MDA-201 provided appropriate details for the preparation of Maintenance Department Procedures and also provided a requirement that review, approval,.and safety evaluations be performed in accordance with STA-202 and STA-70 As noted earlier, STA- ?O2 provides limited guidance on the conduct of technical or nontechnical review STA-707 appears to provide adequate guidance for the performance of safety evaluation The NRC inspector reviewed the manual index for mechanical maintenance procedures and for instrument and control procedures. This review showed that periodic review dates had been assigned as required by STA-203. Further review of ten procedures from'each manua indicated that the periodic

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reviews were curren )

In summary, the applicant has in place an administrative program that provides management controls for safety-related operations activitie Further, the scope of the numerous categories of site procedures addresses the typical operations activities as described in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. A review of selected administrative and implementing procedures indicated that the i administrative program is being complied with for (1) the preparation, review, and approval of procedures, (2) the revision or deletion of procedures, (3) the regulatory requirements for periodic review of procedures, and (4) compliance with 10 CFR 50.59 regarding the performance of ( safety evaluations.

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Specific weaknesses noted in the program were:

. For both the NEO and STA procedures a lack of a clear requirement that procedural changes be evaluated prior to issuance to assure that affected personnel are trained prior to making the change effective.

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" A lack-of a clear definition of the content of procedure reviews, whether technical or non-technica A lack of a requirement to assure that changes to the STA procedures would be evaluated for impact on lower-tier procedures prior to making the changes effectiv La"t of a description of how resolution of comments generated by procedure reviews is accomplished and l T documente The NRC inspector has discussed the preceding four concerns with appropriate plant personne. and considers the concerns to be an open item pending further clarification by the applicant (445/8946-0-02).

1 The NRC inspection assessed the adequacy of administrative controls provided by the CPSES procedural program. No violations or deviations were identified. Adequacy of specific procedures such as security or emergency response procedures are assessed during NRC inspection of those area An additional NRC inspection of the adequacy of site procedures., both administratively and technically, is planned for a future inspection perio . Applicant Meetings (92700)

The NRC inspector attended applicant meetings concerning site i activities and Lnplementation of various site program Meetings attended during this reporting period included: 1

. QA Overview Committee

. Exit for Audit EFE 89-05

. Process for assigning procurement codes No violations or deviations were identified in this area of inspectio I Open Items open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, i and which involve some action on the part of the NRC or ,

applicant or both. Two open items disclosed during this j inspection are discussed in paragraphs 2.a and I

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6.- Exit Meeting.(30703)

.An exit meeting was conducted. July.5,-1989,'with the-

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applicant's' representatives' identified in paragraph.1'of{this

_ repor No written;materialswas provided to'the applicant ~by'

.a the inspectors during'this reporting period. . The. applicant;

did not. identify.as proprietary any..of the' materials.provided-

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to.or. reviewed by the inspectors during this inspection.-

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During this. meeting, the NRC inspectors' summarized the. scope'-

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! and findings.of the:. inspectio .

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