IR 05000445/1990024

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Insp Repts 50-445/90-24 & 50-446/90-24 on 900618-22 & 25-28. No Violations or Deviations Noted.Major Areas Inspected:Self Assessment Capability
ML20055G058
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/11/1990
From: Barnes I, Mcneill W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055G055 List:
References
50-445-90-24, 50-446-90-24, NUDOCS 9007200097
Download: ML20055G058 (8)


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LAPPENDIX

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U.S.: NUCLEAR REGPLATORY COMMISSION-

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REGION IV

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i"tC Inspectibn Report: >50-445/90-24 Operating License: HPF-87 i

50-446/90-24-Construction Permit: CPPR-127

_ Dockets:--50-445

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50-446'

q Licensee: TV El ctric Skyway l Tower F '

_400 North Olive,-L.B. 81 Dallas, Texas 75201-g

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Facility' Name:- -Comanche Peak Steam Electric Station (CPSES)

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q Inspection At: CPSES, Glen Rose,-Somervell County, Texas

' Inspection Conducted: June 18-22, and 25-28, 1990

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? Inspector:

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.W.

M. TcNeill, Reactor Inspeqor, Mat'erials (Tate

dnd Quality Programs Section, Division of-

of Reactor Safety j

]l Approved:

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~7!# bo T. Barnes, Chief,. Materials and Quality Date l

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Programs Section, Division of-Reactor Safety

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inspection'Summarp

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Inspection Conducted June 18-22, 25-28, 1990 (Report 50-445/90-24)

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Areas Inspected: Routine, unannounced inspection of self-assessment capability.

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Results: The Operations Review Committee-(0RC), Station Operations Review Consnittee-(SORC)-and Independent Safety Engineering Group (ISEG) appeared to s

be discharging their_ responsibilities identified in Technical Specifications

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satisfactorily. Some, minor changes-to the ORC Manual were noted to be needed

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-with respect to. clarification of program changes requiring prior ORC approval.

Some additional attention to details in meeting minutes on the part of 50RC Ealso appeared warranted.

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~ Inspectio'n Ccmducted June"18-22.J 25-28,1990 (Reporti 50-446/90-24)

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. Areas Inspected: No ; inspection of. Uni,t' 2 wasl conducted..

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-3-DETAILS

1.

PERSONS CONTACTED-

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1.1 TV ELECTRIC

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J. Amundson,- Station Operations Review Committee (SORC) Secretary

  • J. Barker, In_ dependent Safety Engineering Group-(ISEG) Manager
  • 0. Bhatty, Issue 1 Interface Coordinator-
  • M. Blevins, Manager of Nuclear Operations Support T. Bloom, Compliance Engineer T. Bowman, Office Assistant

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  • J. Buck, Independent Advisor-D. Bushbaum, Compliance Engineer

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G. Davis, Compliance Engineer-

  • G. Edgar,-Legal Counsel A. Husain, Reactor Engineering Director C. Jensen, Operations Review Convaittee (0RC) Secretary
  • J. Kelley, Plant Manager s
  • H. Lawroski, Management Advisor

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-J. Martin, ISEG Engineer

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  • D. McAfee, Quality Assurance ~(QA) Manager

.W. Melton, Administrative Assistant

' *S. Palmer, Project Manager W. Paulson, ISEG Engineer LW.-Preston, ISEG Engineer C. Rice, Training Specialist

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C. Rickgauer',,Results Engineering Supervisor

'K. Scherich, Design Modification Supervisor

  • A. Scott, Nuclear Operations Vice President J..Seawright, Senior Engineer
  • B. Smith, Unit Supervisor B. Taylor, Technical Assistant
  • C. Terry, QA Director,
  • K. Van' Dyne, Site Licensing Engineer

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  • E.-Ottney, Program Manager
  • H. Phillips, Consultant ~

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1.3 NRC

  • W. Johnson, Senior Resident Inspector

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  • Denotes those attending the exit. interview conducted oh June 28, 1990.

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2... LICENSEE SELF-ASSESSMENT CAPABILITY (40500J The objective of this inspection was to evaluate the effectiveness of the licensee's:self-assessment programs.

In this regard, the inspector reviewed the activities of' ORC, SORC, and ISEG with respect to assessment of the effectiveness of these groups in identification of concerns _and following such to resolution.

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'2.1> ORC

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The activities of ORC were governed by the " Operations Review Committee-Manual," Revision 16, dated August 11, 1989.

In addition, ei Interface Department procedures (i.e., TID 3.01 through 3.08)ght Technical addressed how Engineering Services acted as a subcommittee to ORC.

Eagineering Services-reviews'and provides to ORC such agenda items as safety evaluations (SEs); S0RC meeting minutes; QA audits;' Corrective Action Requests; and NRC Generic

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Letters, Bulletins, Notices, and Inspection Reports. The ORC was found to meet about bimonthly.uith one day of the two day meeting held on site. The ORC membership was found to be the Reactor Engineering Director (Chairman), Nuclear i

Licensing Manager, Quality Assurance Director, Engineering Director, Plant Manager, Corporate Health Physics Supervisor, Manager Plant Evaluation, ORC

. Secretary, and.four outside voting members. On the average about 60 agenda items were-addressed at a meeting. A standard format for meetings addressed such agenda items as:

'* Approval.of previous' meeting minutes and Action Item Status Report

QA Monthly Reports, Trends and Analyses

  • ' Operations QA Audits' and Corrective Action Requests Review of Notices of Violations, Licensee Event Reports (LERs), Responses to NRC Bulletins and Inspection Reports Review'of-10'CFR 50.59 SEs T

' Review of Unreviewed Safety Questions, Changes to Technical-Specifications (TSs) and-License Amendments

.-SORC Heeting Minutes

  • . ISEG Activities PlantIncidentReports(PIRs).
  • Nuclear Operation. Month 1) Reports

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Operating Experience Summary Reports i

Other business and special presentations

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-5-The inspector reviewed the 1990 meeting minutes (90-01 through 04) in detail and the qualifications of members and. alternates. Observations by the inspector were as follows:

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.The' qualifications of most members and alternates were found in Final Safety

Analysis Report Chapter 13. The licensee had self identified in ONE forn FX-90-1175 prior to this inspection that records were not available to demonstrate that.0RC members had completed the training requirements referenced in paragraph 2.3.5 of the ORC Manual. Corrective actions have been established to correct this problem.

' The identif.ication and tracking of Action Itens to resolution appeared satisfactory. Thirty-one Action items were initiated in the minutes reviewed, with only.nine of those.found to.be currently open.

The depth ~of discussions and review-of agenda items appeared satisfactory.

In review of meeting minutes, the inspector noted that the ORC approved minutes

=for meeting 90-02 were missing a line of text on the bottom of page 6.

The missing text was the answer to a question from the Citizens' Association for Sound Energy member in regard to a revision-of the ONE Form procedure. The licensee agreed to issue corrected minutes in this regard.

In regard to the conduct of ORC activities, a recent audit (QAA-90-015) of

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ORC had identified a noncompliance with TSs in regard to timeliness of the issuance of meeting minutes and excessive use of alternates. This licensee identified noncompliance was documented on ONE Form FX 90-1513. Corrective-actions have been taken to correct this problem.

  • :The inspector noted that the CPSES Security Plan had been changed (Revision 7), issued,-andimplementedonMay 25, 1990, although it had not been reviewed.and approved by ORC. Paragraph 3.2.6.14 of the ORC Manual requires the review and approval by ORC of all proposed changes to the CPSES Security Plan. Licensee personnel had concluded that the changes were consistent with 10 CFR 50.54(p)(2) in that there was no reduction in plan effectiveness,.and'

prior NRC approval was not required.

It was indicated by licensee personnel that the intent of the ORC Manual was to parallel regulations in this regard and' require prior ORC approval of changes only when a reduction of effectiveness was judged to exist. The' licensee agreed-to change the ORC Manual to define more clearly the conditions requiring prior ORC approval.

This observation was also noted by the inspector to apply equally to the QA program description and to the Emergency Plan. The licensee agreed to make similar clarifications in the planned change to the ORC Manual.

Summary ORC appeared to be discharging the responsibilities identified in TS satisfactorily. -Some minor changes to the ORC Manual were noted to be needed with respect to clarification of program changes requiring prior ORC approval.

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2.2 SORC'

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-The activities of.the SORC were governed by a Station Administration Procedure,

'STA-401', " Station Operations Review Committee," Revision 16, dated August 7, 1989. The SORC. met weekly in regular meetings and held special meetings as

. required by circumstances.

At. regular meetings typically 15 to 50 agenda items o

(averaging 30) were addressed and at special meetings typically one to.10 agenda items were addressed. TheTestReviewGroup(TRG)wasasubcommitteeof SORC for review and approval of test procedures'and results..The TRG was governed by Procedure STA-420, " Responsibilities of the Test Review Group."

' Revision 1, dated January 15, 1990. The TRG meeting minutes were attached to 50RC agendas. As of this inspectica 117 SORC meetings have been held this year. The S0i',C meeting attendance was found to be five to nine members, with usually two alternates. The S0RC membership was found to be the Plant Manager (Chairman), Manager of Nuclear Operations Support, Operations Manager, Maintenance i

Manager.. Plant Support Manager, QA Manager, Instrument and Control (1&C)

Manager, Technical Support Manager, Assistant Radiation Protection Manager, Manager of Site Licensing, Manager of Operation Support Engineering, and SORC Secretary. The meetings addressed such agenda items as:

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Past meeting minutes

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New and revised procedures and their forms

TRG Meeting Hinutes

Take Credit Packages

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TSs and Operating License Changes Design Modifications

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Temporary Modifications

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ONE Forms

.PIRs

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LERs Action item Status Report-

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The insp(ettor reviewed the meeting minutes numbered 90-001 through 108 in detail including associated TRG minutes) and attended regular S0RC V

Meeting 90-116 and Special Meeting 90-117. The training and qualification records of members were reviewed. Observations of the inspector were as follows:

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The qualification and training of SORC members, alternates, and subcommittee members were found 'to be satisfactory with a minor exception. The inspector found that one of the seven TRG members, the QA member, had not received appropriate training in the performance of 10 CFR 50.59; reviews. The charter of this subcommittee, defined in STA-420, requires that the TRG ensure that any changes to the' Initial Startup Program shall have proper 10 CFR 50.59 reviews.

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The' licensee committed to train the individual in question within the next month.

In addition, the procedure will be revised to add 10 CFR 50.59 training to the TRG member training requirements.

The depth of review and discussion of agenda items appeared satisfactory.

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' The inspector was concerned with the relatively large number of procedure

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changes presented during SORC meeting 90-116 which were not on the agenda and distributed prior to,the meeting. Five procedure-changes were identified on-

- the agen.1, with an additional 19 procedures changes being presented during the.

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- SORC. meeting.

The inspector noted instances where the meeting minutes did not clearly

identify the disposition of agenda items. Examples of this were:

agenda item 1, a TSs' interpretation, in meeting 90-064; agenda item 1, a TSs change, in meeting 90-067; agenda item 3, two Temporary Modifications, in meeting 90-074; agenda item 2, three Desion, Modifications, in meeting 90-075;

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and agenda _ items 3 and 4, two ONE forms, in~ meeting 90-087.

In the examples cited the applicable cover sheets or approval sheets for the documents in-question indicated, with the axception of agenda item 3 in meeting 90-087,

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Japproval had been received in tie respective meeting.

In the case of the exception, the ONE form indicated it was not approved in meeting 90-087.

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The SORC Chairman agreed to have SORC attend to the content of meeting minutes-more carefully in the future.

  • The inspector verified that SORC had reviewed and approved all 73 SEs issued as of this inspection in 1990. During this review, an additional discrepancy was noted with respect to meeting minutes. The minutes for meeting 90-003,

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which were approved by the full % in meeting 90-010, identified that SE 90-002 had been tabled untii a future meeting. The conclusion section of the SE indicated, however, that SORC had approved this SE in meeting 90-003.

Review by'the SORC secretary of shorthand notes taken during the meeting-

-confirmed that the SE was approved in meeting 90-003. Corrected meeting minutesihave been issued..

  • The handling of Action Items by SORC and TRG appeared to be generally effective. Of. particular note was the review during regular 50RC meetings of each open Action item by the full committee.

In the meeting minutes reviewed 27 Action Items were initiated, with only 8 being found to be currently open.

During review of SORC meeting minutes the inspector,noted a few cases where Action-Items were established but not identified and tracked as such. Examples of this'were agenda item 3, on a revision of STA-423, in meeting 90-073 and agenda item 2, on an interpretation of TSs, in meeting 90-093.

Summary

.The SORC appeared to be. discharging the responsibilities identified in TS satis.factorily. Some attention to details in meeting minutes on the part of

50RC appears warranted.

.2.3 ISEG The' activities of ISEG were found to be governed by procedures TID 3.01 through 3. 0 5.- ISEG was staffed with five engineers and a manager and reported to the Technical Interface Director. The ISEG's activities included:

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i Plant tours reported as observations of activities in such areas as control I

room operations, auxiliary operator, mechanical maintenance electrical

s maintenance,1&C, radiation protection, chemistry, testing, and training.

Special studies reported as evaluations of such subjects as operating

l experience (both in-house and industry wide), warehouse, chemistry releases, surveillance procedures, and self-assessment for powr:r ascencion.

o The inspector reviewed monthly ISEG activity. reports and schedules for 1990, and the 91 observations and four evaluations issued es of the date of this

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inspection. The training and qualification records'of the ISEG staff were also reviewed.

It was noted that 64.recomendations had been made by ISEG of which 31 were open..

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In review of ISEG Evaluation reports, the inspector.noted that certain problems identified by ISEG during an evaluation were documented on ONE forms, deficiency i

reports and other types of nonconformance documents, rather than as ISEG recomendations. The report details referenced these nonconformance documents but also referenced other nonconformance documents issued before the evaluation, in these cases the report sumary and recommendation sections did not identify the nonconformance documents generated because of the ISEG activity, it m peared to the inspector that reference to these nonconformance documents in

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the report sumary and recommendation sections would provide a more. visible

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record of the results of ISEG evaluation activities.

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Sumary ISEG appeared to be discharging the responsibilities in ntified in the T5 satisfactorily.

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No violations or' deviations were identified in this aspection.

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EXIT INTERVIEW.

  • An exit meeting was held June 28, 1990, with personnel indicated-in paragraph 1

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'of this report. At this meeting, the scope of-the inspection and the findings

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were sumarized. The licensee did not identify as proprietary any of. the

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,infennation provided to, or reviewed by, the inspector.

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